EPA DOCKET NO. A-98-49, II-A4-142

WASTE CHARACTERIZATION INSPECTION

CONTINUED COMPLIANCE REPORT

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJ ECT

WASTE CHARACTERIZATION PROGRAM

AT THE IDAHO NATIONAL LABORATORY

November 16-17, 2010

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

February 2011i TABLE OF CONTENTS

1.0 Executive Summary .................................

................................................... ........................ 1

2.0 Purpose of Continued Compliance Inspections .......

................................................... ........ 1

3.0 Purpose of This Report ............................

................................................... ........................ 2

4.0 Scope of This Continued Compliance Inspection .....

................................................... ....... 2

5.0 Personnel .........................................

................................................... ................................. 3

5.1 EPA Inspection Team ...............................

................................................... ........... 3

5.2 Personnel Contacted................................

................................................... ............. 4

6.0 Technical Evaluation of the Waste Characterization Areas ............................................. .. 5

6.1 Acceptable Knowledge ..............................

................................................... .......... 5

6.1.1 Contact-Handled Waste Streams ..................... ........................................... 5

6.1.2 Remote-Handled Waste Streams ...................... ........................................ 29

6.1.3 Summary of Acceptable Knowledge Results ........... ................................ 39

6.2 Nondestructive Assay ..............................

................................................... .......... 39

6.2.1 Technical Evaluation: Waste Assay Gamma Spectromete r...................... 40

6.2.2 Technical Evaluation: Super High Efficiency Neutron Counter .............. 43

6.2.3 Summary of Nondestructive Assay Results ........... ................................... 45

6.3 Real-Time Radiography .............................

................................................... ........ 46

6.4 Visual Examination ................................

................................................... ............ 47

7.0 Summary of Results and Conclusions ................

................................................... ........... 48

7.1 Findings and Concerns .............................

................................................... .......... 48

7.2 Tiering Changes ...................................

................................................... .............. 48

7.3 Conclusions .......................................

................................................... ................. 49

LIST OF TABLES

Table 1. EPA Inspection Team Members ..............

................................................... ...................... 3 Table 2. Personnel Contacted During Inspection ....

................................................... .................... 4 Table 3. Contact-Handled Batch Data Reports Examine d ................................................. ............. 7 Table 4. Original Lawrence Berkeley National Labora tory Drum Numbers ............................... 2 0 Table 5. Summary of Accelerated Retrieval Project D rum Traceability Analysis ....................... 2 0 Table 6. Remote-Handled Batch Data Reports Examined

.................................................. .......... 30 Table 7. Summary of Compliance with Tiering Require ments ............................................. ....... 36ii ATTACHMENTS
Attachment A Real-Time Radiography Concern No. IN L-CCP-CH-RTR-10-01CR
Attachment B.1 Replicate Testing Data for Drum ARP2 1969 -WAGS
Attachment B.2 Replicate Testing Data for Drum ARP2 2225 - WAGS
Attachment B.3 Replicate Testing Data for Drum BN10 381564 - SuperHENC
Attachment C.1 Acceptable Knowledge References – Co ntact-Handled Waste

Attachment C.2 Acceptable Knowledge References – Re mote-Handled Waste

Attachment C.3 Nondestructive Assay References – Co ntact-Handled Wasteiii ACRONYMS AND ABBREVIATIONS

AEC Atomic Energy Commission

AK Acceptable Knowledge

AKE Acceptable Knowledge Expert

AKSR Acceptable Knowledge Summary Report

Am americium

AMWTP Advanced Mixed Waste Treatment Project

ANL-E Argonne National Laboratory-East

ARP Accelerated Retrieval Project

ASTM American Society for Testing and Materials

Ba barium

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Project

Cf californium

CH contact-handled

CIS characterization information summary

cps counts per second

CRR Characterization Reconciliation Report

Cs cesium

CWI CH2M-WG Idaho, LLC

DOE U.S. Department of Energy

DPS Drum Packaging Stations

DQO data quality objective

DR discrepancy resolution

DU depleted uranium

EA Expert Analyst

EPA U. S. Environmental Protection Agency

FQAO Facility Quality Assurance Officers

FR Federal Register

FRAM Fixed-energy Response Function Analysis with M ultiple Efficiencies

FWHM Full Width at Half Maximumiv

g/cm 3 grams per cubic centimeter

GEM Glovebox Excavator Method

HENC High Efficiency Neutron Counter

HERL Heavy Elements Research Laboratory

HEU highly enriched uranium

HFEF Hot Fuel Examination Facility

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Cent er

IQT Image Quality Test

ITR Independent Technical Review

keV kilo electron volt

LBNL Lawrence Berkeley National Laboratory

LLD Lower Limit of Detection

LO Lead Operator

LOQI List of Qualified Individuals

LLNL Lawrence Livermore National Laboratory

LWA Land Withdrawal Act

MCS Mobile Characterization Services

MFP Mixed Fission Products

MGA multi-group analysis

mrem/hr millirem per hour

nCi/g nanocuries per gram

NCR Nonconformance Report

NDA Nondestructive Assay

NDE Nondestructive Evaluation

NNSS Nevada National Security Site

Np neptunium

NRF Naval Reactors Facility

NTS Nevada Test Site

NU natural uranium

NWPA Nuclear Waste Policy Act of 1982

OJT on the job training

OM Operations Managerv

ORIA Office of Radiation and Indoor Air

PCB polychlorinated biphenyl

PDP Performance Demonstration Program

PM Project Manager

PPE personal protective equipment

PTS Project Tracking System

Pu plutonium

QAPD Quality Assurance Program Document

QC quality control

R&D Research and Development

RDS Radioassay Data Sheet

RFETS Rocky Flats Environmental Technology Site

RFP Rocky Flats Plant

RH remote-handled

RTR Real-Time Radiography

RWMC Radioactive Waste Management Complex

SCG Summary Category Group

SDA Subsurface Disposal Area

SHENC Super High Efficiency Neutron Counter

SPC sludge pan container

SPM Site Project Manager

SQS Small Quantity Site

Sr strontium

SHENC Super High Efficiency Neutron Counter

SWB standard waste box

SWEPP Stored Waste Examination Pilot Plant

T1 Tier 1

T2 Tier 2

TMU total measurement uncertainty

TRA Test Reactor Area

TTR Tonopah Test Range

TTR-HET Tonopah Test Range- Heterogeneous

TRU transuranicvi

U uranium

VE Visual Examination

VEE Visual Examination Expert

VERB Visual Examination and Repackaging Building

VET Visual Examination Technique

VPM Vendor Project Manager

WAGS Waste Assay Gamma Spectrometer

WC Waste Characterization

WCPIP Waste Characterization Program Implementation Plan

WDS Waste Data System

WG weapons-grade

WIPP Waste Isolation Pilot Plant

WMC Waste Matrix Code

WMP Waste Material Parameter

WSPF Waste Stream Profile Form

WTS Washington TRU Solutions1

1.0 EXECUTIVE SUMMARY

In accordance with 40 CFR 194.24(h), the U.S. Envir onmental Protection Agency (EPA) conducted a continued compliance inspection of the Central Characterization Project (CCP) waste characterization program for contact-handled (CH) and remote-handled (RH) transuranic (TRU) wastes at the U.S. Department of Energy (DOE) Idaho National Laboratory (INL) in Idaho Falls, Idaho. This inspection occurred on Nov ember 16-17, 2010. In accordance with the provisions of 40 CFR 194.24(h), as issued in a July 16, 2004, Federal Register (FR) notice (69 FR 42571–42583), EPA conducted a continued comp liance inspection of the site’s program to characterize TRU wastes proposed for disposal at the Waste Isolation Pilot Plant (WIPP). As a result of this continued compliance inspection, EPA confirmed that the INL-CCP TRU waste characterization program continues to characterize CH and RH TRU waste consistent with the

conditions and limitations that are discussed in th e baseline inspection reports (see EPA Docket Nos. A-98-49; II-A4-59 and A-98-49; II-A4-72). Duri ng this inspection, EPA evaluated samples of the following waste characterization activities:

• Acceptable knowledge (AK) for CH and RH waste strea ms

• Two nondestructive assay (NDA) systems operated by INL-CCP for characterizing CH TRU wastes: the Waste Assay Gamma Spectrometer (WAG S) and the Super High Efficiency Neutron Counter (SuperHENC)

• Real-time radiography (RTR) for CH retrievably stor ed TRU debris waste (S5000)

• Visual Examination (VE) for newly generated CH and RH TRU waste

EPA maintains its approval of the INL-CCP CH and RH TRU waste characterization programs in the configuration observed during this inspectio n consistent with the limitations described in the baseline inspection reports cited above and oth er subsequent EPA Tier 1 (T1) approvals. The T1 and Tier 2 (T2) designations from the baseline i nspection and other subsequent EPA T1 approvals remain applicable and no T1 or T2 tiering changes resulted from this continued compliance inspection.

This report serves as EPA’s public notification of the results of the continued compliance inspection. This information will be provided throu gh the EPA website and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8( b)(3).

2.0 PURPOSE OF CONTINUED COMPLIANCE INSPECTIONS

Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, FR notice, EPA must perform a single baseline inspection of a TRU waste generator site’s waste characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on a demonstration that the program’s components, with applicable condition s and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.2

Following EPA’s baseline approval, EPA has the auth ority to conduct continued compliance inspections to verify that the site continues to us e only the approved waste characterization processes to characterize the waste and remains in compliance with all the regulatory requirements. EPA is also authorized to evaluate an d approve changes, if necessary, to the site’s approved waste characterization program by conducti ng additional inspections under the authority of 40 CFR 194.24(h).

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s decision to maintain the approval of the INL-CCP waste characterization program for CH and RH TRU wa stes. Specifically, this report does the following:

• Describes the sample of the INL-CCP waste character ization systems evaluated during this inspection

• Identifies all areas where waste characterization s ystems have changed relative to what was approved during the baseline inspection and oth er subsequent EPA T1 evaluations, and assesses the impact, if any, of those changes

• Provides objective evidence to support the EPA cont inued approval basis for all waste characterization systems

• Describes any tests or demonstrations completed dur ing the course of the inspection and their relevance to EPA’s approval decision.

The DOE documents that EPA reviewed for this evalua tion are cited in different sections throughout the report and are listed in Attachments C.1 through C.3. Any of these documents can be requested from the following address:

Carlsbad Field Office Manager, National TRU Program

P.O. Box 3090 Carlsbad, NM 88221-3090

4.0 SCOPE OF THIS CONTINUED COMPLIANCE INSPECTION

The scope of this continued compliance inspection i ncluded the evaluation of selected elements of the waste characterization systems in use at INL -CCP to characterize CH and RH TRU wastes that were approved during the baseline inspection a nd subsequent T1 evaluations. The EPA inspection team evaluated aspects of these systems with respect to their ability to continue to perform the following functions:

• Identify and quantify the activities of the 10 WIPP -tracked radionuclides [americium-241 ( 241 Am), cesium-137 ( 137 Cs), plutonium-238 ( 238 Pu), 239 Pu, 240 Pu, 242 Pu, strontium-90 ( 90 Sr), uranium-233 ( 233 U), 234 U, and 238 U] using a combination of AK and NDA systems3

• Assign waste material parameters (WMPs) correctly u sing RTR and VE for CH and RH retrievably stored and newly generated wastes, resp ectively

Specifically, these consisted of the following comp onents:

• AK processes that support CH and RH wastes

• Two NDA systems, the WAGS and SuperHENC systems

• RTR for retrievably stored CH wastes

• VE for newly generated CH and RH wastes

The evaluation consisted of interviewing personnel, observing equipment operations that follow site procedures, and inspecting records related to each of the waste characterization processes within the inspection’s scope. An important aspect of this evaluation was the objective evidence documenting the effectiveness of the waste characte rization processes. Objective evidence typically takes the form of batch data reports (BDR s), radioassay data sheets, AK accuracy reports and RTR tapes. During this inspection, EPA selected samples of each of these items, based on the number and variety of items each waste characterization process produced, consistent with standard inspection techniques. Bas ed on the evaluation of the waste characterization processes in conjunction with the samples of objective evidence, EPA determined the technical adequacy of the waste char acterization processes within the inspection’s scope.

5.0 PERSONNEL

5.1 EPA Inspection Team

Table 1 identifies the members of the EPA waste cha racterization inspection team.

Table 1. EPA Inspection Team Members

Inspection Team Member Position Affiliation

Ed Feltcorn Inspector-Team Leader U.S. EPA ORIA a
Rajani Joglekar Inspector U.S. EPA ORIA Lindsey Bender Inspector U.S. EPA ORIA Cathy Economy Observer U.S. EPA ORIA Patrick Kelly NDA Inspector SC&A, Inc. Dorothy Gill RTR Inspector SC&A, Inc. Connie Walker AK Inspector SC&A, Inc. Kira Darlow AK Inspector SC&A, Inc. Rose Gogliotti NDA Observer SC&A, Inc.

a Office of Radiation and Indoor Air4

5.2 Personnel Contacted

EPA and its support personnel conducted interviews with INL-CCP waste characterization personnel in several disciplines. The personnel con tacted represented a sample of the CH and RH TRU waste characterization staff, and they are listed in Error! Reference source not found.

, with their affiliations and areas of expertise or f unction.

Table 2. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise/Function

Scott Smith TechSpecs/INL-CCP AKE

Lisa Frost CWI ICP

Tom Johnson CWI STR
Stephanie McElhaney Pajarito SHENC-EA

Courtland Fesmire CBFO Observer

Michael Walentine WTS/CCP Project Office PM

Thomas L. Clements, Jr. CWI ICP

Irene Quintana WTS/CCP RH PM

Ted Carlson WTS/INL-CCP VPM

Greg Smith WTS/INL-CCP VPM

Tyson Christenson VJ Technologies RTR

Rick Green Pajarito SHENC

Howard Budweg CBFO Observer

Jeffrey Poole WTS/INL-CCP VEE

Preston Abbott MCS NDA, EA

Bart Morales MCS NDA-EA

Bill Verlanic WTS/INL-CCP Site PM

Bryce Woodbury MCS NDA-EA

Mark Pearcy WTS/CCP Project Office Certification Manager

Corey Boland MCS NDA-LO

Sharon Cummins Pajarito NDA—SuperHENC, Operator

Shane Boudreau Pajarito NDA—SuperHENC, EA

James Rowsell MCS NDA—WAGS, Operator

John Braiser MCS NDA—WAGS, EA

Jerry Bowden VJ Technologies RTR Operator, ITR

Brett Gyorfy Stoller RTR Operator, ITR

Vince Medina WTS/INL-CCP SPM5

6.0 TECHNICAL EVALUATION OF THE WASTE CHARACTERIZATION AREAS

Sections 6.1 through 6.4 of this report detail the four technical areas assessed during this inspection: acceptable knowledge (AK); nondestructi ve assay (NDA); and nondestructive examination (NDE), consisting of real-time radiogra phy (RTR) and visual examination (VE).

6.1 Acceptable Knowledge

6.1.1 Contact-Handled Waste Streams

Background Information

EPA examined the AK process and associated informat ion to determine whether INL-CCP remained in compliance with 40 CFR 194.8 requiremen ts for CH waste streams. The continued compliance inspection scope included all of the Sma ll Quantity Site (SQS) and three Accelerated Retrieval Project (ARP) waste streams. Specifically , EPA reviewed the following CH waste

streams:

• ID-NTLBL-S3900

• ID-NTLBL-S5400

• ID-NTS-TTR-HET

• ID-SDA-DEBRIS

• ID-SDA-SLUDGE

• ID-SDA-SOIL

Small Quantity Site Waste Streams

EPA approved the INL-CCP CH baseline program in Oct ober 2005 for S3000, S4000, and S5000 waste. In 2008, INL-CCP began accepting waste from offsite SQS generators for characterization and subsequent shipment to WIPP. S everal sites have shipped waste to INL for characterization as SQSs— Nevada National Security Site 1 (NNSS) was a main storage area for waste from several SQSs including Lawrence Livermor e National Laboratory (LLNL), Lawrence Berkeley National Laboratory (LBNL), Lynch burg, Industrial Technology Research Institute, Rocky Flats Environmental Technology Sit e (RFETS), 2 the Tonopah Test Range (TTR)

and related test facilities at or near NNSS. NNSS i tself also generated waste [e.g., waste created during repackaging at the NNSS Visual Examination a nd Repackaging Building (VERB) facility]. INL-CCP accepts waste directly from Smal l Quantity Sites (SQS) including LLNL, LBNL, and General Electric Vallecitos. EPA examined the SQS characterization process with an emphasis on AK data assembly, use, and interpretati on to assess whether these wastes have been appropriately characterized under INL-CCP’s approve d program.

Accelerated Retrieval Project Waste Streams

1 The Nevada National Security Site was formerly nam ed the Nevada Test Site.

2 The Rocky Flats Environmental Technology Site was formerly known as the Rocky Flats Plant (RFP).6

Over the years, INL received TRU waste from several onsite and offsite DOE locations [e.g., Argonne National Laboratory West, and Rocky Flats P lant (RFP)], as well as other generators (e.g., Colorado School of Mines, and the United Sta tes Geologic Survey). These wastes were placed in the subsurface disposal area (SDA). The S DA at INL consists of 58 trenches, 20 pits, 21 rows of soil vaults, Pad A, and the Acid Pit, wh ere historic waste disposal activities occurred. Waste in certain areas of the SDA has been targeted for removal under the ARP, and the areas containing the targeted waste are collectively iden tified as the “retrieval area.” The waste removal, drumming, and characterization for WIPP di sposal are occurring in a phased manner [Phases I (ARP-I) through V (ARP-V)]. The retrieved ARP wastes are divided into three waste streams during VE: ID-SDA-DEBRIS, ID-SDA-SLUDGE, an d ID-SDA-SOIL. EPA has approved these INL-CCP Summary Category Groups (SCG s) for WIPP disposal.

During this continued compliance inspection, EPA pr imarily evaluated Revision 9 of the AK Summary Report (AKSR), but also included specific s ections of Revisions 7 and 8 of the AKSR to confirm that INL-CCP continues to comply with th e EPA-approved AK processes when integrating additional ARP phases into the AK recor d.

EPA conducted a continued compliance inspection at INL-CCP during September 2008, and later in October-December 2008. EPA’s report, dated March 2009, identified as a T1 change the following (see EPA Docket No. A-98-49): “Changes to the targeted waste(s) from what was presented in Revision 6 of the AK Summary CCP-AK-IN L-001.” CCP-AK-INL-001, Revision 7, approved by CBFO on October 27, 2008, r evised the targeted waste to incorporate the previously non-targeted RFP 742-sludge. This ap proval occurred while EPA’s continued compliance report was in preparation, and was imple mented before EPA’s T1 requirement was documented. EPA elected to postpone review of the i nclusion of 742-sludge until the next continued compliance inspection. The analysis is pr esented in Item (1) below.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the element s of the AK process listed below:

• Waste stream definition

• AK information pertaining to the radiological chara cteristics of TRU wastes

• Identification of wastes’ physical form, including waste material parameters (WMPs) and prohibited items

• AK procedural adequacy and implementation, i.e., as sembly compilation, interpretation, confirmation, and discrepancy resolution

• Adequacy of the AKSR

• Drum traceability and the ability to follow the AK waste characterization process

• Defense origin of TRU wastes

• Spent Nuclear Fuel (SNF) and High Level Waste (HLW) status relative to the Land Withdrawal Act (LWA)7

• Waste Stream Profile Form (WSPF) preparation and co mpleteness

• Preparation of nonconformance reports (NCRs)

• AK accuracy

• Implementation of load management

• NDA-AK communication.

Documents, Waste Containers, and Batch Data Reports Reviewed

As part of this continued compliance inspection att achments, source documents, required forms, and other data were provided to EPA and were examin ed, as appropriate. All CH AK

documentation referenced is listed in Attachment C. 1. Some of these documents were provided in advance of the inspection, however most were pro vided to EPA upon arrival at INL-CCP. The

list of VE and NDA BDRs examined for this evaluatio n is presented in Table 3.

Table 3. Contact-Handled Batch Data Reports Examine d

Waste Stream Drum Number NDE BDR Number NDA BDR Number

ID-NTLBL-S3900 NT080018R INRTRS090049 INNDAS090184

ID-NTLBL-S5400 NT041489A INRTRS090058 INNDAS09218

ID-NTS-TTR-HET TTR-21A INRTR5090059 NNDAW090179
ID-SDA-DEBRIS ARP06227 INARPVE000740 INNDAH080058, INNDAW090184

ID-SDA-SLUDGE ARP15566 INARPVE001510 INNDAS090352

ID-SDA-SOIL ARP20413 INARPVE001936 INNDAS100048

Technical Evaluation

EPA examined three SQS waste streams and three ARP waste streams. Adequacy of

documentation and identification of the waste strea ms are addressed below. Throughout the review, the three ARP waste streams may be evaluate d as one because they are differentiated only by their physical characteristics.

(1) The definition of waste stream was evaluated and fo und to be adequate.

Contact-Handled Wastes Streams from Small Quantity Sites:

As part of this inspection, EPA evaluated three SQS waste streams. These waste streams have been characterized and disposed at WIPP and INL-CCP informed EPA of the availability of WSPFs as T2 changes in the Q1 2010 Tier Report. EPA reviewed the information provided and included the three SQS waste streams listed below i n this inspection.

ID-NTLBL-S5400 debris from Lawrence Berkeley Nation al Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

The waste stream originated from research and devel opment (R&D) and maintenance activities at LBNL. Source documents (References U001, U015, U 029, U052, U072, U074, U084, and U103) suggest that drums from the waste stream had original closure dates from 1975–1980 and8

were shipped to NNSS between May 1975 and December 1984. The waste stream originally consisted of 12 drums, seven of which were overpack ed into 85-gallon drums and directly shipped to WIPP from NNSS. NNSS repacked the remain ing five drums, resulting in one 55- gallon S5400 drum, one S5400 standard waste box (SW B), and one 55-gallon S3900 drum (discussed below as a separate waste stream) (Refer ences DR002, P025, U015, U072, U074, U084, and U103).

The AKSR and related source documents indicate that the waste stream was generated primarily as part of ongoing actinide chemistry research in t he Heavy Elements Research Laboratory (HERL) in Building 70A and its predecessor in Build ing 70 (P098). Source documents (e.g., C101) suggest the waste in this waste stream origin ated from the Pitroom (Building 70). The AKSR states that the following divisions were opera ting during the time of waste generation:

• Chemistry Division, 1961 through 1963

• Nuclear Chemistry Division, 1964 through 1974 (P098 )

• Materials and Molecular Research Division, 1975 thr ough 1986 (Reference P098)

The AKSR implies that wastes generated between 1976 and 1996 from the Nuclear Science Division may be present based on the dates of activ ities. The AKSR also suggests that waste generated from 1977 and 1995 by the Earth Sciences Division to support the development of nuclear waste repositories, specifically WIPP and Y ucca Mountain could also be present in the waste (Reference P098).

INL-CCP stated that any activities performed prior to 1975 may have contributed to this waste stream, as 1975 was the date of the first drum clos ure, not the date of first generation of this waste. No waste generated after 1980 would be in th e waste stream. INL-CCP indicates that waste cannot be differentiated by generator locatio n because wastes were comingled at a single collection point. Based on the process description and general information provided by INLCCP, the waste stream is appropriately defined. Phy sical and radiological characteristics of the waste stream are described in Items (2) and (3) bel ow.

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Waste Stream ID-NTLBL-S3900 originated from R&D and maintenance activities performed at LBNL (References U001, U015, U029, U072, and U103). The waste stream is mixed homogeneous solids originally generated from 1977 t o 1980, which are the closure dates of the original NTLBL drums containing solid waste. The wa ste stream consists primarily of absorbed and solidified aqueous liquids. The materials used to absorb/solidify liquids include Aquaset, diatomaceous earth, Portland cement, and vermiculit e. This waste has the same process origin as ID-NTLBL-S5400, but was generated when the original four drums were repackaged and S3900 waste was segregated into a separate one-drum waste stream. Waste Stream ID-NTLBL-S3900 consists of a single drum and no additional contain ers of this waste stream will be generated in the future. Based on this information, the waste st ream is adequately defined; see Items (2) and (3) below for additional information.9

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

The Roller Coaster Project involved storage transpo rtation tests conducted at the Double Tracks located at the Nellis Air Force Range and the Clean Slate 1, 2, and 3 sites located on the TTR. Conventional explosives were used to detonate nucle ar materials and study their distribution.

These two areas were contaminated with Pu and U and were remediated in 1994–2000, resulting in the collection of metal fragments and other debr is such as personal protective equipment (PPE) (References C1002, C1003, P1017, P1013, and P 1025). Two 30-gallon drums of TRU debris waste were generated and these were shipped to NNSS for storage at the TRU Pad Cover Building in December 1999. Approximately 3,550 gram s of hot fragments were collected and are in the debris waste, with a measured 241 Am activity in excess of 100 nanocuries per gram (n Ci/g) (References C1002, M1005, P1012, P1013, P1014, P102 4, P1025, P1033, P1036, P1099, and P1107). The TTR-HET drums were repackaged into a si ngle 55-gallon drum at the VERB in 2006 (References C1014 and P1016). Based on this in formation, while the wastes were obtained from two separate areas, the processes associated w ith their creation are similar and their commingling during repackaging makes it impossible to distinguish them by production areas. The waste stream is adequately defined, see Items ( 2) and (3) below for additional information.

In addition to the three SQS waste streams, ARP was te streams were evaluated, as described

below.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

The targeted waste in all five ARP phases (ARP-I – ARP-V) consists of RFP First-Stage Sludge (741-Series), RFP Second-Stage Sludge (742-Series), RFP Organic Setups (743-Series), RFP Roaster Oxide, RFP Graphite, and RFP Filters. The p its contained within ARP-III, -IV, and -V received waste from RFP during the same time period as the previously approved waste (May 1964 – September 1968, compared to January 1963 – S eptember 1968), indicating that the wastes have the same origin (References ID-P092, ID -U343, ID-U344, ID-U345, INTEC-P002, RF-U1306, RF-U1307, and RF-U1308). Waste Stream ID- SDA-DEBRIS is defined as a separate

waste stream because it contains more than 50% debr is. Waste Stream ID-SDA-SLUDGE is defined as a separate waste stream from the rest of the ARP waste because it contains more than 50% sludge. Waste Stream ID-SDA-SOIL is defined as a separate waste stream because it

contains more than 50% interstitial soil from the r etrieval area. Based on this information, the waste streams are adequately defined; see Items (2) and (3) below for additional information.

Evaluation of the Inclusion of Rocky Flats Plant Se cond-Stage Sludge (742-Series) as Targeted Waste from the Accelerated Retrieval Proje ct

The 741- and 742-series sludges were generated in R FP Building 774, which treated aqueous solutions contaminated with highly enriched uranium (HEU), depleted uranium (DU) and Pu containing trace amounts of 241 Am, neptunium-237 ( 237 Np,) 233 U, and curium-244 ( 244 Cm). The treatment activities performed in Building 774 used a two-stage precipitation process. The first stage contained the bulk of the radioactive constit uents and was designated as 741-series sludge.10

The first-stage effluent was collected as feed for the second-stage precipitation process; sludge collected from second-stage precipitation was desig nated a 742-series sludge (second-stage sludge) (Reference P562). RFP 741-series inorganic sludges were included in the original targeted waste population, but the 742-series sludg es were not because targeted wastes were limited to those expected to contain a significant portion of the constituents of concern, specifically volatile organic compounds, U, and TRU radionuclides, including Pu. INL-CCP later determined that the 741- and 742-series sludg es are generally physically indistinguishable; therefore, INL-CCP decided to include the 742-serie s sludge in the targeted population because it was typically comingled with the excavated targeted waste (References P216, P239).

EPA examined references to determine the radiologic al differences between the two sludges. The data provided indicates that the 741-series sludge is expected to include the bulk of the actinides present in the waste stream, primarily 239 Pu, 241 Am, and 240 Pu by mass, while the 742-series sludge is expected to contain far less Pu and other actinides, and more U (References P256, U115). 741-series sludge also contains over 63% of the TRU activity, while 742-series sludge contains less than 0.2% of the TRU activity (Refere nce P103). The treatment process may preferentially concentrate more soluble radionuclid es in the 742-series sludge than in the 741- series sludge.

INL-CCP included radiological data for all wastes i n the overall radiological envelope expected for the SDA waste streams, including non-targeted m aterials, as discussed in Section 5.5 of the AKSR and presented in Table 5-4. INL-CCP also adjus ted the AK-NDA memorandum (included in Attachment 7 of CCP-TP-005) between Revisions 6 and 9 of the AKSR to include new ARP phases; APR-III and -IV include more 742-series slu dge by volume and the isotopic data presented in the AK-NDA memorandum should reflect t his change. Changes to the estimated radionuclide mass and activity percents for the was te stream as a whole due to addition of ARPIII and -IV were relatively small. The eventual add ition of ARP-V waste to the AK-NDA memorandum should not impact the estimated values g reatly, due to the relatively low volumes of 741- and 742-series sludge expected in ARP-V. EP A also notes that 742-series sludge was generated from the same general process as the 741- series sludge, and agrees that while the radiological composition of the 742-series sludge i s different, the overall composition fits the anticipated ARP radiological composition (AKSR Tabl e 5-4), which was developed to include all targeted and non-targeted wastes. EPA agrees th at the 742-series sludge was included in the waste stream because it was indistinguishable from 741-series sludge, and believes this may account for the large number of INL-CCP Nonconforma nce Reports (NCRs) issued due to drums exhibiting TRU activity <100 nCi/g. EPA concludes t hat the 742-series sludge fits the previously defined radiological envelope of the ARP wastes, an d has been accounted for in recent AK-NDA

memoranda with the inclusion of ARP-III and ARP-IV waste.

Modification of the targeted waste population remai ns a T1 change.

(2) Acceptable Knowledge information pertaining to the radiological characteristics of

transuranic wastes was examined and found to be ade quate.

Radiological characteristics of each waste stream w ere evaluated as described below.11

Contact-Handled Waste Streams from Small Quantity S ites ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Experiments and activities conducted at LBNL result ed in wastes containing a wide variety of radionuclides. LBNL was not a production facility, so constant isotopic ratios for Pu are not expected (References C101, P025, P094, U001, U003, U029, U061, U067, and U085). Radionuclides that may be present include the follo wing:

• 241 Am, 243 Am

• Berkelium-249

• Californium-249, 252

• 242 Cm, 244 Cm

• 237 Np

• Protactinium-231

• 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu

• Radium-226

• Thorium-228

• Mixed fission products, assumed to include 137 Cs and 90 Sr

Based on NNSS NDA measurements of the two container s in the waste stream, the predominant radionuclides by weight percent are 237 Np at 56.61% and 241 Am at 18.54%. Greater than 95% of the total activity is 241 Am and 241 Pu. Previous assay data from NNSS show that 234 U and 238 U are not expected (References C142 and U103). This infor mation does not coincide with INL-CCP NDA data, which indicates that 239 Pu and 241 Am are the predominant radionuclides by weight,

and INL-CCP submitted a freeze file 3 change to the AKSR to address this discrepancy. Th e NDA memorandum for this waste stream states that se veral Pu grades were commonly used at
LBNL; grades are defined by their percentage composition of 240 Pu and 241 Am (except for heatgrade Pu). The NDA memorandum provided default isot opic distributions for weapons-grade (WG), fuel-grade, reactor-grade, mixed-grade, and a mericium-enriched plutonium, enriched

uranium and DU. The NDA memorandum states that if i sotopic analysis results are not acceptable or available, default isotopics as defin ed in AK are used. In the case of drum No. NT041489A, which was examined as part of this conti nued compliance inspection, the NDA analyses used AK-based default isotopics as defined in the AK-NDA memorandum. See Item (11) below for additional information pertaining to AK accuracy and Item (14) below for additional information pertaining to AK-NDA communi cation. Based on data reviewed and INLCCP assay information, the radiological composition of the waste stream is adequately defined.

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory and stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revision 0)

3 As a result of an inspection-related EPA issue, INL -CCP may have to revise a document. INL-CCP makes t he change(s) and provides the revised document to EPA as a freeze file to serve as objective evidence for the inspection. INL-CCP’s document control process then generates an official version of the revised docum ent.12

Waste Stream ID-NTLBL-S3900 consists of mixed homog eneous solids generated at LBNL as part of R&D and maintenance activities and is compo sed primarily of absorbed and solidified aqueous and organic liquid. Aquaset, diatomaceous e arth, Portland cement, and vermiculite were used to absorb/solidify liquids. The radionuclide c omposition of the waste stream was based on NDA measurements performed at the NNSS indicating t hat the predominant radionuclides for this waste stream by weight are 239 Pu (90%) and 240 Pu (6.15%), and that over 95% of the total activity is 239 Pu, 240 Pu, and 241 Pu. The NDA memorandum indicates that default isoto pics will be used in the event that measured values are unaccept able. In the case of the single drum in the waste stream, measured isotopics were acceptable. B ased on data reviewed and INL-CCP assay information, the radiological composition of the wa ste stream is adequately defined.

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

Waste Stream ID-NTS-TTR-HET was generated from the remedial investigations and the cleanup of Double Tracks and Clean Slate sites. At these sites, high explosives were detonated near nuclear weapon assemblies to determine contami nation dispersion. The assemblies were composed of 238 Pu, 239 Pu, 240 Pu, 241 Pu, and DU, and debris associated with the waste co ntain

these radionuclides and 241 Am, a decay product of 241 Pu (References C1002, P1012, P1013, P1014, P1017, P1018, P1023, P1032, P1033, P1096, P1 107, and P1099). Container TTR-21A was radioassayed at NNSS in 2006 and was determined to be TRU, i.e., >100 nCi/g TRU alpha activity. Based on the results of this assay, the t wo predominant radionuclides expected by weight percent based on AK are 238 U and 239 Pu, while 241 Pu, 239 Pu, and 240 Pu comprise over 95% of the total activity. This information does not co incide with INL-CCP NDA data which

indicates that 239 Pu and 240 Pu are the predominant radionuclides by weight, and INL-CCP submitted a freeze file change to the AKSR rectifyi ng this discrepancy. The AK-NDA memorandum stated that if measured isotopic results were not available, default isotopics would be used. In the case of the single drum, TTR21A, me asured isotopics were used. INL-CCP

measurement data indicate that 239 Pu and 241 Am are the most prevalent isotopes by weight. See Item (11) below for additional information pertaini ng to AK Accuracy and Item (14) below for additional information pertaining to AK-NDA communi cation. Based on EPA’s analysis, the radiological composition of the waste stream was ad equately defined.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

While each ARP phase contains targeted RFP waste, t he proportion and type of targeted and non-targeted wastes waste types in each area varies , as do the SQSs that contribute to each ARP. The waste retrieval and VE processes attempt to rem ove as much of the non-targeted waste as possible; however, some contamination is inevitable . Therefore, the expected radionuclides in ARP waste streams must be updated every time a new ARP phase is added. INL-CCP calculates the expected radionuclides based on AK data (Refere nce ID-U313), and continues to update these calculations every time additional ARP phases are added, historically adding one new ARP phase per AKSR revision, as evidenced by comparing Tables 5-2, 5-3, and 5-4 in AKSR, Revisions 7, 8, and 9. INL-CCP indicates that the m ost prevalent radionuclide by mass are 238 U (99.63%), with 235 U and 239 Pu as the second and third most prevalent by mass i n almost equal13

concentrations, while the most prevalent radionucli des by activity are 241 Pu (50.56%) and 241 Am (38.07%). During this continued compliance inspecti on, EPA noted that the AK-based expected radionuclides do not accurately correspond with tho se measured by NDA. This appears to be because INL-CCP is not adequately correcting for th e in-growth of 241 Am from 241 Pu. 4 EPA recognizes that INL-CCP has not historically been r equired to update the radiological

characterization information in the AKSR based on N DA information. Instead, the AK-NDA memorandum is expected to reflect accurate, NDA-bas ed information and the AK Accuracy Reports are expected to catch inconsistencies betwe en the AKSR and the NDA records. See Items (11) and (13) below for further discussion of this issue. Based on the above information, the AK information pertaining to the radiological c haracteristics of TRU wastes is adequate.

(3) Identification of physical form, including Waste Ma terial Parameters and prohibited items, were assessed and found to be adequate.

Contact-Handled Waste Streams from Small Quantity S ites

ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Waste Stream ID-NTLBL-S5400 is composed of mixed, h eterogeneous decontamination and decommissioning and process/maintenance related was tes generated at LBNL, appropriately classified as WMP S5400. Specific waste items inclu de organic laboratory debris (cardboard, cloth tape, cotton swabs, Kimwipes, paper) and inor ganic debris (aluminum, copper, glass, graphite, and other scrap metals). The AKSR states that the drum(s) may contain 241 Am sources with lead shielding, but sources were not found dur ing repackaging. Small amounts of sorbent may be present. INL-CCP estimated the WMP based on NNSS RTR and VE of six containers shipped directly from NNSS to WIPP (Reference C134) . INL-CCP determined that the waste stream is composed primarily of inorganic waste, su ch as metals (79.7%), with the remainder composed of organic material, such as cellulosics ( 20.3%). Comparison of these data with the

RTR results for drum NT041489A indicates that this drum contains materials that generally correspond with those identified in legacy drums. T ypical materials include scrap metal, hand tools, springs, metal cans, wire, metal funnels, ho se clamps, open metal buckets, metal clamps, scrap lead, small glass containers, absorbent, ligh t bulbs, labware, wood, plastic bags, scrap plastic, and plastic sheeting. Based on the above a nalysis, the physical composition of the waste stream was adequately described.

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Waste Stream ID-NTLBL-S3900 is composed of homogeno us solids generated through solidification of liquids associated with LBNL R&D and process/maintenance activities. It is composed primarily of absorbed or solidified aqueou s liquids generated through mixing with Aquaset, diatomaceous earth, Portland cement, and v ermiculite. Debris may also be present in the waste stream. It is appropriately assigned WMC S3900, Unknown/Other Homogenous Solids

4 With a half-life of 14.35 years, 241 Pu decays to 241 Am at a rate of approximately 4.7% per year, i.e., 241 Am accumulates at a rate of approximately 4.7% per yea r.14

(References C101, P094, U014, and U103). INL-CCP ev aluated pre-screen RTR information performed at NNSS to estimate WMP percentages and c ontent information compiled in supporting AKSR CCP-AK-NTS-003. Based on this analy sis, INL-CCP estimated that the waste stream was composed primarily of inorganic (92.54%) and organic materials (7.46%).

Examination of Attachment 6 and associated memorand a, as well as the container RTR performed by INL-CCP, indicates that the drum conta ins a plastic bag, plastic containers, and sludge (percentages were not provided on the RTR fo rm). This description generally conforms with AK. The physical composition of the waste stre am was adequately described.

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

Waste Stream ID-NTS-TTR-HET is composed primarily o f debris and other site remediationrelated waste, as well as a small amount of soil co ntaining metal fragments. Specific debris items include PPE and sampling equipment such as plastic gloves and bags, boot covers, disposable coveralls, wipes, foil, respirator cartridges, mask ing tape, and disposable sampling tools (References C1002, C1024, M1005, M1025, P1099, P110 7, U1010, and U1011). INL-CCP indicated that VE forms were not prepared by NNSS w hen this waste stream was repackaged and consolidated, and the waste generation processes su ggested that the waste may contain substantially more soil than presented in the AKSR. However, the AK references examined verify that the waste stream is composed primarily of debris (80%), with some soil and metal (20%). WMC S5400, Heterogeneous Debris, was assigne d to the waste stream (References C1024, M1025, U1010, and U1011). WMP estimates were obtained based on the assumptions

that:

• The soil component contains both soil and metal fra gments of equal weight

• The weight percents are 50% metal fragments (iron b ased metal/alloys), 25% aluminumbased metals/alloys and 25% other metals.

Based on the descriptions of PPE and sampling equip ment from AK source documents, the debris component is estimated to contain by weight 30% cellulosics, 30% plastic, 30% rubber, 5% iron-based metal/alloys, 3% other metals, and 2% aluminum-based metals/alloys (References P1099 and P1107). Examination of RTR data for drum No. TTR21A indicates that it is composed of scrap metal, scrap rubber, plastic bags , plastic sheeting, plastic tubing, large open plastic containers, and soil, which corresponds to the anticipated waste content determined by AK. Based on the above analysis, the physical compo sition of the waste stream was adequately

described.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

The three ARP waste streams are debris (ID-SDA-DEBR IS), solid/sludge (ID-SDA-SLUDGE), and soil (ID-SDA-SOIL). An ARP waste drum may conta in any of these three wastes and these

materials are delineated into the three waste strea ms bases on the WMP associated with more than 50% of the drum’s contents, as discussed under Item (1), above.15

The AKSR describes the targeted debris waste as gra phite and filters. Solid targeted wastes are:

• 741- and 742-series sludges – inorganic solid matri ces derived from treatment of aqueous liquids that were solidified through the addition o f Portland cement

• 743-series sludge – an organic solid matrix derived from the treatment of oils and organic solvents into a solid by mixing with a synthetic ca lcium silicate and organic solvents

• Roaster oxides – pure DU metal machine turnings con verted to an oxide in a chemical roaster that INL-CCP classifies as a homogenous sol id waste

Soils are not targeted waste, however, many of the targeted debris and sludge wastes are no longer (or were never) buried in drums or container s and quantities of the interstitial dirt are inadvertently removed from the retrieval area and p ackaged with the targeted wastes.

As described in Item (2) above, the volumes of targ eted wastes are included in the different ARP phases in varying proportions to other targeted and non-targeted wastes. Therefore, INL-CCP periodically updates the estimated waste burial vol umes and WMP percentages based on expected contents of the newly added ARP areas and the VE records of waste packaged from ARP-I and -II (References ID-U-329 and ID-U345). Wh ile the percentage of targeted waste in the entire retrieval area did not change with the a ddition of ARP-III, -IV, and -V, the proportions estimated in the various areas vary widely. The tot al volume of ARP-I and ARP-II is currently estimated at 225,087 ft 3 (85,046 ft 3 less than estimated in AKSR, Revision 6), of which 33% is targeted waste and 67% is non-targeted waste (10% m ore and 10% less, respectively, than estimated in AKSR, Revision 6). In total, ARP-III, -IV, and -V add a total of 361,159 ft 3 , of which 17% is targeted waste and 83% is non-targeted waste. Addition of the newer ARP phases

increased the total waste volume but did not increa se the percentage of targeted waste.

Analysis of the information provided by INL-CCP ind icates that the intended physical characteristics of the debris, solid, and soil wast es in the new ARP phases and ARP-I and -II should be comparable for targeted wastes. Data sugg est that there are no major anomalous nontargeted materials. However, 100% VE is performed d uring waste packaging to verify the absence of prohibited items, identify anomalous ite ms, catalogue WMPs, and assign the drum to the appropriate waste stream. The physical composit ion of the waste stream was adequately

described.

(4) Acceptable Knowledge procedural adequacy and implem entation were assessed and found to be adequate (assembly compilation, interpr etation, confirmation, discrepancy resolution).

INL-CCP uses procedure CCP-TP-005 for AK data colle ction, analysis, interpretation, confirmation, and discrepancy resolution. INL-CCP h as used Revision 18 of this procedure since 2008, but this procedure was recently updated and t he current revision is 20. EPA expected revision 20 to include information formerly include d in the WCPIP for RH waste (Revision 0D), which was removed and placed in procedure CCP-TP-00 5 during the most recent revision of the16

WCPIP. However, Revision 20 does not include these requirements, which should only impact RH waste. EPA reviewed changes to CCP-TP-005, as pr esented in Revisions 19 and 20:

• Revision 19: This revision incorporated relatively minor changes identified during internal and external audits. Typical revisions inc lude changes to source document titles and simplification of attachment references. A nota ble change is the addition of a requirement to return generator site documents to t he generator site once INL-CCP no longer works at that site, rather than include thos e references in INL-CCP Records. This was apparently due to the number of site documents assembled as part of the AK program. EPA understands this simplification, but C BFO must ensure EPA has access to these documents regardless of the characterization entity that uses (or used) the documents. For example, it is possible that INL-CCP could lose their certification, at which point records typically included in INL-CCP’s files would no longer be available at INL-CCP Records. EPA expects that all documents will be readily available to EPA regardless of storage location. Additionally, INL-C CP revised language to no longer require that the Attachment 3 summaries be “attache d” to their associated source documents. This practice of separating Attachment 3 summaries from the full source document proved burdensome at other CCP sites becau se the Attachment 3 forms were assigned the exact same document number as the orig inal source document. If the two files were mixed, it would be impossible to tell th e original source document from the summary. If the Attachment 3 summaries are separate d from the original source documents, EPA expects that these files will have u nique identifiers such that the source

documents and summaries can be differentiated.

• Revision 20: This document revision includes minor modifications, the most notable being a requirement to submit each AKSR revision to INL-CCP Document Services.

Revisions 19 and 20 of CCP-TP-005 did not significa ntly modify the AK process, and are acceptable noting the above items.

Contact-Handled Waste Streams from Small Quantity S ites (AKSRs CCP-AK-INL-010, Revision 0 and CCP-AK-INL-01 4, Revision 0)

EPA also reviewed the confirmation checklists for t he three SQS waste streams to determine if any issues requiring a discrepancy resolution (DR) and reevaluation checklist arise during the confirmation process. Waste Stream LBNL S3900 did n ot require AK re-evaluation based on characterization data. However, both the TTR-HET an d LBNL S5400 waste streams

reevaluation checklists noted issues that mandated AK reevaluation.

• For LBNL S5400, 239 Pu and 241 Am are the most prevalent radionuclides by weight b ased on measurement data, not 237 Np and 241 Am as indicated by AK. An AK reevaluation was requested, and an Attachment 10 (reevaluation check list) was finalized on November 9, 2010. This explained the discrepancy, and indicated that the AKSR will be updated to recognize this change. The AKSR is dated July 2009, so the next revision of this AKSR

should include the modification based on the DR and AK re-evaluation.17

• For TTR-HET, 239 Pu and 240 Pu are the most prevalent radionuclides by weight b ased on measurement data, not 238 U and 239 Pu as indicated by AK. An AK reevaluation was requested, and an Attachment 10 was completed Janua ry 7, 2010. This re-evaluation resulted in the generation of DR1005. The AKSR is d ated June 18, 2009, so the next

revision of this AKSR should include the modificati on based on the DR and AK reevaluation.

Notification of revisions to any SQS AKSR remains a T2 change.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

EPA also reviewed random confirmation checklists fo r the three ARP waste streams to determine if any issues requiring issuance of DRs a nd/or reevaluation checklists arose during the confirmation process. Waste Stream ID-SDA-DEBRIS di d not require AK reevaluation. However, both the ID-SDA-SLUDGE and ID-SDA-SOIL was te streams have reevaluation checklists noting issues associated with tentativel y identified compounds that mandated AK

reevaluation. The reevaluation checklist for the ID -SDA-SLUDGE waste stream was noted during a previous continued compliance inspection. The soil reevaluation checklist, completed one year later, lists additional compounds but desc ribes the same solution. The AKSR was not revised as a result of either discrepancy. Notifica tion of revisions to the AKSR remains a T2 change.

(5) The Acceptable Knowledge Summary Report was assesse d and found to be adequate.

AK summaries for each of the waste streams were eva luated, as summarized below.

Contact-Handled Waste Streams from Small Quantity S ites

ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Waste Stream ID-NTLBL-S5400 consists of mixed heter ogeneous debris generated at LBNL as part of R&D and maintenance activities. INL-CCP sta tes that the waste stream is composed of organic and inorganic laboratory debris. See Item ( 3) above for additional detail. AK indicates that some drums may contain 241 Am sources with lead shielding, but VE did not iden tify these items. Small amounts of homogenous solids may be pr esent, but the vast majority of this waste material type was removed during repackaging and pl aced in the S3900 waste stream. AK indicated that the two predominant radionuclides by mass are 237 Np and 241 Am, while over 95% of the total activity is 241 Am and 241 Pu. However, as indicated in Items (2) and (4) abov e, INLCCP’s NDA data showed that 240 Pu was a predominant radionuclide by mass, so the A KSR must be revised to address this discrepancy. Additionall y, the AKSR did not adequately address the defense determination explanation; see Item (7) bel ow for additional information. As detailed in Item (6) below, INL-CCP submitted a freeze file cha nge describing drum traceability elements. EPA expects the AKSR to be revised to reflect all o f these deficiencies and notification of availability of this revision remains a T2 change.18

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Waste Stream ID-NTLBL-S3900 is mixed homogenous was te generated during R&D and process/maintenance activities at LBNL. See Item (3 ) for additional detail. The waste was originally comingled with debris generated by the s ame activities, but was separated into a different waste stream during repackaging at NNSS. AK data suggest that the two predominant radionuclides by mass are 239 Pu and 240 Pu, and over 95% of the total activity is 239 Pu, 240 Pu, and

241 Pu, which was confirmed by NDA. However, as indicat ed in Item (7) below, the AKSR did not adequately address the defense origin of wastes . As detailed in Item (6) below, INL-CCP submitted a freeze file change describing drum trac eability elements. The AKSR must be revised to better justify the defense determination and to address the traceability change and notification of availability of this revision remains a T2 chang e.

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

Waste Stream ID-NTS-TTR-HET is composed of waste ge nerated through cleanup of two sites in Nevada at which U- and Pu-bearing materials were exploded using conventional explosives. The waste consists of heterogeneous debris waste wi th lesser amounts of soil containing metal fragments. See Item (2) above for additional detail . The AKSR states that the two predominant radionuclides by weight are 238 U and 239 Pu, while over 95% of the total activity is 239 Pu, 240 Pu,

and 241 Pu. However, NDA measurements found the two predomi nant radionuclides by weight to

be 239 Pu and 240 Pu. As indicated in Items (2) and (4) above, the AK SR should be revised to address this discrepancy. Notification of availabil ity of a revised AKSR remains a T2 change.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

These ARP waste streams consist of targeted RFP deb ris and sludge wastes and may also contain

interstitial soil. While the historic source of all the targeted waste is RFP, various small generators also contributed waste to the ARP. Every time a new ARP area is added, INL-CCP continues to adequately update the list of potentia l waste generators, the expected radionuclides, WMP estimates, and the list of AK source documents. For example, in AKSR, Revision 9, INLCCP described three additional INL waste generators relative to ARP-V (Pit 9): CFA-665 – the Vehicle Maintenance Terminal and Automotive Repair Shop, the Modular Analytical Laboratory, and the Glovebox Excavator Method (GEM) Project. The Modular Analytical Laboratory will only contribute wastes (including u naltered sample material) generated during analysis of the ARP wastes (References ID-P402, ID- P403, ID-P404, ID-U376, and ID-U377). The GEM project tested the methods to be utilized t hroughout the ARP retrieval area by excavating a portion of Pit 9 (now ARP-V); the wast es removed by the GEM project will be repackaged and sorted into the three ARP waste stre ams (References ID-C114, ID-P377, IDP380, ID-P399, ID-U355, and RF-P356). As described in Items (2) and (3) above, INL-CCP adequately revised the AKSR, Revision 9 to account for the expansion of the retrieval area to

include ARP-V. Sufficient source documents were add ed to the AK record to support inclusion of ARP-V. The CCP-TP-005, Attachment 4, AK Summary Document Reference List has not yet19

been updated to include references in the AKSR, Rev ision 9. EPA assumes that this document will be updated in the future.

(6) Drum traceability and the ability to follow the Acc eptable Knowledge waste characterization process for containers were evalua ted and found to be adequate.

Contact-Handled Waste Streams from Small Quantity S ites

Retrievably stored and newly generated containers w ere evaluated separately. Traceability of retrievably stored containers from LBNL to NNSS to INL was examined to verify that a drum’s history could be tracked to the place of origin. To streamline the inspection, traceability was performed on the LBNL wastes only, although examine d references indicate that a similar level of traceability is available in the AK record for t he TTR-HET waste stream.

ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0), and ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory st ored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revision 0)

Traceability of drums from the two LBNL waste strea ms was evaluated by interviewing INLCCP representative Scott Smith. Since the container s have a common origin they were evaluated in tandem and the results are presented together. T he final drums of interest are Nos. NT041489A (S5400) and NT080018R (S3900) and were pa rt of 12 that originated from the Building 70 Pitroom and were originally loaded betw een 1975 and 1980. These 12 drums were shipped to NNSS, beginning in 1975; seven were dire ctly shipped to WIPP, while five drums were retained because they required repackaging. Th ese five drums (Nos. NT280011, NT280007, NT280015, NT780025, and NT751050) were re packaged in 2008, resulting in one debris drum (No. NT041489A), one debris SWB, and on e homogenous solids drum (No. NT080018R). It must be noted that the AKSR states f our drums, not five, were retained and repackaged at NNSS. EPA noted the discrepancy in dr um numbers while performing the traceability analysis and INL-CCP submitted a freez e file modification to Section 4.5.1 of the

AKSR. EPA evaluated the freeze file modification an d found it acceptable. Notification of availability of a revised AKSR that includes this r evision remains a T2 change.

Traceability of LBNL Drum No. NT280011 was examined . This drum was generated at LBNL in 1980 and shipped to NNSS. It underwent RTR at NN SS in 2005 upon repackaging it to drum “A” in July 2005, and a second repackaging to drum “AA” in October 2005. The drum was then assayed in June 2006, and was repackaged again in 2 009 placed in a SWB, and shipped to INL. References U103, U065, U016, U051 and U001 were amo ng those examined to verify this progression. INL-CCP provided the information prese nted in Table 4 below that identifies original LBNL drum numbers:20

Table 4. Original Lawrence Berkeley National Labora tory Drum Numbers

Waste Stream Drum Number

Shipped to INL Feed

Drum Number Interim

Drum

Number Interim

Drum

Number Drum Number

Shipped to

NNSS

ID-NTLBL-S5400 NT080344R NT280011AA NT280011A NT28 0011

HC-05-065A NT042090A NT042090 NT280007

NT980100 NT280015

NT780025A NT780025

NT041489A NT041489 NT751050

ID-NTLBL-S3900 NT080018R NT780025A NT780025

NT280011A NT280011

Additionally, INL-CCP provided a list of source doc uments and identified the pages in those

source documents that addressed the LBNL waste trac eability; source documents U014, U015, U051, U061, U065, U067, U084, and U085 were include d in this listing. These data indicate that traceability could be achieved for the complex hist ory associated with the two S5400 containers and single S3900 drum that originated at LBNL. Noti fication of availability of a revised AKSR that includes revisions related to drum repackaging remains a T2 change.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

The three ARP waste streams are composed entirely o f newly generated waste; therefore, there is no direct link between waste generation at generato r site and the drums being characterized by INL-CCP. However, through use of the Waste Inventor y Location Database at INL and other historic waste documentation, INL-CCP is able to id entify the specific wastes that were interred in the pits by ARP phase. EPA evaluated traceabilit y for the last drum from each ARP waste stream that was emplaced in the WIPP facility as of the date of the continued compliance inspection. VE and NDA BDRs, relevant NCRs, project tracking system (PTS) screenshots, and WDS Container Data Reports were provided for each d rum. Each drum was traceable from generation during VE through NDA to final emplaceme nt in the WIPP facility, as summarized

below in Table 5.

Table 5. Summary of Accelerated Retrieval Project D rum Traceability Analysis

Drum No. SCG VE BDR, date NDA BDR, date –

result 2 nd NDA BDR, date –

result Emplacement Date

ARP06227 S5400 IN-ARP-VE-000740,

2/11/08 INNDAH080058,

2/20/08 – rejected,

NCR-INL-0159080 INNDAW090184,

7/30/09 – reworked,then accepted, NCRINL-052610 11/10/10

ARP15566 S3900 IN-ARP-VE-001510,

4/9/09 INNDAS090352,

11/23/09 – accepted N/A 11/12/10

ARP20413 S4200 IN-ARP-VE-001936,

3/8/10 INNDAS100048,

3/17/10 – accepted N/A 11/7/1021

(7) Defense origin of transuranic wastes was examined a nd found to be adequate.

Contact-Handled Waste Streams from Small Quantity S ites

ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0) and ID-NTLBL-S3900 solid waste from Lawrence Berkeley National Laboratory st ored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revision 0)

INL-CCP states that since 1931, LBNL has been invol ved with TRU research and development, including technologies important to the development of the first atomic bombs. From 1947 to 1975, the Atomic Energy Commission (AEC) was respon sible for and funded programs in nuclear weapons research, development, production, and testing, as well as projects related to

radioactive materials and TRU radionuclides. INL-CC P also states that budget documents generated from 1957 through 1986 identified numerou s programs and projects that can be tied to

defense activities.

INL-CCP states that based on guidance from the DOE, a TRU waste is eligible for disposal at WIPP if it has been generated in whole or part by o ne of the atomic energy defense activities listed in Section 10101(3) of the Nuclear Waste Pol icy Act of 1982 (NWPA). INL-CCP attempted to demonstrate that the TRU waste destine d for disposal at WIPP is associated with defense activities by linking TRU waste items to re searchers, LBNL divisions, and facilities that were associated with defense work that generated th e wastes (Reference P098). INL-CCP

concluded that there was a sufficient correlation o f defense activities to those performed at LBNL to support a defense determination for waste g enerated at this facility. CBFO issued an approved defense determination for LBNL waste shipp ed to LLNL in April 2004, and INL-CCP stated that this was applicable to the LBNL waste s hipped to NNSS since it was within the time frame of generation of the LBNL wastes assigned to Waste Streams ID-NTLBL-S5400 and IDNTLBL-S3900 (Reference P098).

EPA reviewed source documents associated with the L BNL waste streams and noted that the defense determination was not supported by some of these references. Specifically, Reference C101, which is an interview with operators who perf ormed experiments in the Building 70 Pitroom during the 1975–1980 time period, states th at activities performed at this location were non-defense in origin. EPA questioned the INL-CCP A KE about these assertions, and received an adequate explanation. Since the wastes originate d prior to 1975, DOE contends that this waste is likely to be contaminated with defense-related r adionuclides. EPA also expects that when the

AKSR and Reference C101 and other references that d iscuss the defense determination are revised, notification of availability of a revised AKSR and corresponding references is necessary and it remains as a T2 change.

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

Based on guidance from the DOE, a TRU waste is elig ible for disposal at WIPP if it has been generated in whole or part by one of the atomic ene rgy defense activities listed in Public Law22

102-579, The Waste Isolation Pilot Plant Land Withdrawal Act (as amended), and Section 10101(3) of the NWPA. INL-CCP concluded that AK ind icated the TRU waste generated from the Roller Coaster Project is contaminated from act ivities related to weapons, defense nuclear waste and materials by-products management, and def ense research and development. EPA accepts DOE’s conclusion.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

The AKSR, Revision 9 was assessed with respect to t he defense origin of these wastes. Targeted waste in the additional ARP phases came from RFP an d EPA previously established RFP’s involvement with weapons-related activities, thus m eeting the defense-related criterion. With regard to the non-targeted waste, EPA previously de termined that the targeted and non-targeted wastes within the three waste streams were commingl ed due to a lack of container integrity within the pits. This situation is no different in ARP-III, -IV, or -V than it was in ARP-I and -II. Therefore, the defense arguments posed by INL-CCP c ontinue to be acceptable to EPA and supported by available documentation.

(8) The absence of Spent Nuclear Fuel and High Level Wa ste Status in these waste streams was evaluated and found to be in compliance with th e Land Withdrawal Act

.

The AKSRs for all evaluated waste streams indicate the following: “The Public Law 102-579, [WIPP LWA] prohibits the disposal of spent nuclear fuel and high-level waste as defined by the [ Nuclear Waste Policy Act (NWPA)]... at WIPP.” According to the NWPA, spent nuclear fuel (SNF) is “fuel that has been withdrawn from a nucle ar reactor following irradiation, the constituent elements of which have not been separat ed by reprocessing.” DOE Order 435.1, Radioactive Waste Management (Reference 16) expands on this definition to clarify that “test specimens of fissionable material irradiated for re search and development only, and not production of power or plutonium, may be classified as waste, and managed in accordance with the requirements of this Order when it is technical ly infeasible, cost prohibitive, or would increase worker exposure to separate the remaining test specimens from other contaminated material.” High-level waste (HLW) is defined by the NWPA as “the highly radioactive material resulting from the reprocessing of spent nuclear fu el, including liquid waste produced directly in reprocessing and any solid material derived from su ch liquid waste that contains fission products in sufficient concentrations, and other highly radi oactive material that the commission, consistent with existing law, determines by rule requires perm anent isolation.”

The waste stream contents and descriptions were eva luated against these definitions to determine

whether the waste streams contained SNF or HLW.

Contact-Handled Waste Streams from Small Quantity S ites

ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)23

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

The NTLBL-S5400 and NTLBL-S3900 waste streams consi st of debris and homogeneous waste "contaminated with radioactive material from R&D, m aintenance, and repackaging operations." INL-CCP indicates that these operations did not inc lude any separation or reprocessing of reactor fuel, and the wastes themselves do not contain irra diated fuel elements from a reactor; spent fuel pieces or particles also are not included in the wa ste. INL-CCP concludes, and EPA agrees, that the three containers in the subject waste streams d o not include SNF and are not HLW (Reference P098).

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

Operation Roller Coaster and remediation of the Rol ler Coaster test sites and Roller Coaster RADSAFE Area involved the dispersion of nuclear mat erial through detonation of conventional chemical explosives. References provided to EPA did not indicate that the Pu and U sources used were "spent nuclear fuel." The waste stream does no t include HLW as defined by the NWPA (References P1008, P1016, and P1022).

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

As evaluated in the last continued compliance inspe ction at INL, the AKSR, Revision 9 adequately explains that Waste Streams ID-SDA-DEBRI S, ID-SDA-SLUDGE, and ID-SDASOIL do not contain SNF or HLW. The AKSR states tha t SNF may have been buried in Pit 4, but not in the retrieval area, and that if SNF is f ound it will be segregated and not packaged. No NCRs have been generated since 2006 due to the pres ence of intact fuel rods. The AKSR also states that while HLW (acidic liquids) were produce d in one of the small waste-contributing generators (CCP-601), it was sent to a different fa cility and not buried in the retrieval area. EPA continues to accept INL-CCP’s position that ARP was te streams do not contain SNF or HLW.

(9) Waste Stream Profile Form preparation and completen ess were evaluated and found to be adequate.

The WSPFs for each of the waste streams were examin ed for completeness. Note that none of the WSPFs examined had a change request form indica ting that modifications were requested after initial approval.

Contact-Handled Waste Streams from Small Quantity S ites

ID-NTLBL-S5400 debris from Lawrence Berkeley Nation al Laboratory and stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Michael Walentine approved the WSPF on October 23, 2009; the Characterization Information Summary (CIS) was attached, including the AK Summat ion of Aspects. The approved WSPF was complete.24

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

Michael Walentine approved the WSPF on October 23, 2009; the CIS was attached, including the AK Summation of Aspects. The approved WSPF was complete.

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

Michael Walentine approved the WSPF on November 18, 2009; the CIS was attached, including the AK Summation of Aspects. The approved WSPF was complete.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (Acceptable Knowledge Summary Report CCP-AK-INL-001, Revision 9 )

Barbara Broomfield approved the ID-SDA-DEBRIS WSPF on February 21, 2007; the CIS is attached, including the AK Summation of Aspects. Th e approved WSPF is complete.

Barbara Broomfield approved the ID-SDA-SLUDGE WSPF on February 25, 2007; the CIS is attached, including the AK Summation of Aspects. Th e approved WSPF is complete.

Barbara Broomfield initially approved the ID-SDA-SO IL WSPF on June 17, 2008; the CIS was attached, including the AK Summation of Aspects. Ho wever, the AK Summation of Aspects appeared to be missing the first two pages. Other t han the missing pages, the approved WSPF was complete. In 2009, the WSPF was revised in resp onse to New Mexico Environment Department comments. Michael Walentine approved the ID-SDA-SOIL WSPF, Revision 1, on October 7, 2009 by; the CIS is attached, including all pages of the AK Summation of Aspects. The approved revised WSPF is complete.

(10) Preparation of nonconformance reports was evaluated and found to be adequate.

Contact-Handled Waste Streams from Small Quantity S ites (AKSRs CCP-AK-INL-010, Revision 0 and CCP-AK-INL-01 4, Revision 0)

INL-CCP provided a spreadsheet that identified the NCRs issued at INL since 2006. Based on this spreadsheet and the BDRs provided for Waste St reams NTLBL-S5400, NTLBL-S3900, and TTR-HET, NCRs were not prepared for any drums exami ned within these waste streams.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

EPA has evaluated INL-CCP’s ability to produce comp liant NCRs several times. As a spot check, EPA reviewed the two NCRs associated with dr um traceability data for S5400 drum No. ARP06227. INL-CCP generated NCR-INL-0159080 because this drum assayed at less than 100 nCi/g of TRU and was returned to INL. A year later, NCR-INL-052610 was generated during a25

second NDA analysis of this drum because of an issu e with the 238 Pu activity. This drum underwent review by the NDA expert analyst (EA), th e Independent Technical Reviewer (ITR) and Site Project Manager (SPM), and finally was acc epted for disposal at WIPP. These two NCRs indicate that INL-CCP continues to produce NCR s according to EPA-approved procedures.

(11) Acceptable Knowledge accuracy was assessed and foun d to be adequate.

Contact-Handled Waste Streams from Small Quantity S ites

ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

EPA reviewed the AK accuracy report for Waste Strea m NTLBL-S5400, and found that it contained typographical errors. EPA also found that the predominant radionuclides identified by AKSR and NDA did not correspond, but the AK accurac y report did not reflect this discrepancy. Instead, the AK accuracy report stated that NDA and AK data were in agreement, with 100% accuracy. INL-CCP representatives explained that at the time the AK accuracy report was prepared, a freeze-file change was in place that up dated the AKSR by revising the predominant radionuclides to correspond to those identified thr ough INL-CCP NDA.

The NDA results and AK information in place at the time of AK accuracy report preparation, including the AKSR, must be compared to determine r adiological accuracy. The freeze file change was in place prior to the NDA-AK comparison. In the future, AK accuracy reports must state whether a pending freeze file or other docume ntation was reviewed in addition to the AKSR. If a freeze file change or other documentatio n was not in place at the time of the review to explain differences between NDA and the AKSR, th en INL-CCP must evaluate NDA-AKSR discrepancies as radiological inaccuracies. INL-CCP provided a revised AK accuracy report, approved on January 7, 2010, that rectified the typ ographical errors, but this version did not state that the AK accuracy review included AKSR freeze-fi les. EPA also believes that INL-CCP should consider both radionuclide weight percent an d activity percent when evaluating AK accuracy and will revisit this issue in the future. Providing AK accuracy reports for this waste stream remains a T2 change.

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

EPA reviewed the AK accuracy report for Waste Strea m NTLBL-S3900 that states that 239 Pu and

240 Pu are the two most prevalent radionuclides, which was verified by NDA performed by INLCCP. No Attachment 10s were prepared for this waste stream (AK-reevaluation). The AK accuracy report concluded that the accuracy for thi s waste stream was 100% because there was no reassignment of WMC and no addition of new hazar dous waste numbers, and because the radionuclide composition determined by measurement is consistent with AK. This appears reasonable since the radionuclide content assigned by AK was verified by INL-CCP’s NDA measurements. As stated previously, EPA believes th at INL-CCP should consider both26

radionuclide weight percent and activity percent wh en evaluating AK accuracy and will revisit

this issue in the future.

ID-NTS-TTR-HET debris sourced from the Tonopah Test Range/Roller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-0 14, Revision 0)

EPA reviewed the AK Accuracy Report for Waste Strea m NTS-TTR-HET, and questioned how CCP-TP-005, Attachment 10 was addressed. INL-CCP re presentatives adequately explained the discrepancy. EPA also found that the AKSR and NDA-i dentified predominant radionuclides did not correspond, but the AK accuracy report did not reflect this discrepancy and instead stated that NDA and AK data were in agreement, with 100% a ccuracy. INL-CCP representatives explained that at the time the AK accuracy report w as prepared, a freeze-file change was in place that updated the AKSR by revising the predominant r adionuclides to correspond to those identified through CCP-INL NDA. However, the freeze file was prepared on January 10, 2011, and was not in place at the time the AK accuracy re port was prepared and INL-CCP did not provide information to support their contention tha t AK reviewed at the time of AK Accuracy Report preparation supported NDA results.

The NDA results and AK information in place at the time of AK accuracy report preparation, including the AKSR, must be compared to assess accu racy. AK accuracy reports must state whether a pending freeze file or other documentatio n was reviewed in addition to the AKSR. If a freeze file change or other documentation was not i n place at the time of the review to explain differences between NDA and the AKSR, then INL-CCP must evaluate NDA-AKSR discrepancies as radiological inaccuracies. As stat ed previously, EPA also believes that INLCCP should consider both radionuclide weight percen t and activity percent when evaluating AK accuracy and will revisit this issue in the future. INL-CCP must revise the AK accuracy report for Waste Stream ID-NTS-TTR-HET to accurately refle ct the AK data in the record at the time of report preparation. Providing AK accuracy report s for this waste stream remains a T2 change.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

INL-CCP provided AK Accuracy Reports for ID-SDA-DEB RIS Lots 1-28, ID-SDA-SLUDGE Lots 1-185, and ID-SDA-SOIL Lots 1-37. None of the AK accuracy reports identified any issues with respect to WMPs or radionuclides and all three reports indicate that the most prevalent radionuclides by mass are 238 U and 239 Pu, consistent with AK. However, since actual weigh t percentages are not given, it is impossible to comp are the predicted and actual values. All three reports state that no drums were rejected due to ra dionuclide-related concerns. As mentioned in Item (2) above and Item (13) below, the AK record d oes not include the in-growth of 241 Am from

241 Pu, but this discrepancy between expected and NDA-m easured values is not reflected in the AK accuracy report. EPA determined that this is bec ause the discrepancy is apparent when comparing radionuclide activity percentages, which the AK accuracy report does not evaluate. As stated previously, EPA believes that INL-CCP sho uld consider both radionuclide weight percent and activity percent when evaluating AK Acc uracy and will revisit this issue in the

future.27

EPA also notes one minor typographical error in the Soil AK accuracy report (one of the section headings references incorrectly ID-SDA-DEBRIS” inst ead of “ID-SDA-SOIL”), and assumes

that this will be corrected before the next version is available. Providing AK accuracy reports for the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS w aste streams remains a T2 change.

(12) Load management was examined and found to be not ap plicable.

Contact-Handled Waste Streams from Small Quantity S ites

ID- NTLBL-S5400 debris from Lawrence Berkeley Natio nal Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

ID-NTS-TTR-HET debris from the Tonopah Test Range/ Roller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

The WSPFs for these three waste streams state that load management will not be employed for these waste streams. Implementation of load managem ent remains a T1 change.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

INL-CCP has previously indicated, and EPA has previ ously observed, that load management is not being performed. During this continued complian ce inspection, INL-CCP stated that load management had not been implemented. Implementation of load management continues to be a T1 change.

(13) NDA-AK communication was assessed and found to be a dequate.

Contact-Handled Waste Streams from Small Quantity S ites

ID-NTLBL-S5400 debris from Lawrence Berkeley Nation al Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

ID-NTLBL-S3900 solid waste from Lawrence Berkeley N ational Laboratory stored at Nevada National Security Site (AKSR CCP-AK-INL-010, Revisi on 0)

INL-CCP issued the same AK-NDA memorandum for the N TLBL-S3900 and NTLBL-S5400 waste streams on June 25, 2009. Jim Shoen prepared the memorandum which states, “The purpose of this memorandum is to satisfy the requir ement of CCP-TP-005, INL-CCP Acceptable Knowledge Documentation, for evaluating the radionu clide characterization of LBNL TRU mixed waste streams ID-NTLBLS5400: Heterogeneous De bris and ID-NTLBL-S3900: Solidified Inorganics and Organics.”28

The AK-NDA memorandum stated that INL-CCP expected that the isotopic codes MGA or

FRAM 5 provide reasonable estimates of the isotopic distr ibution. However, if acceptable isotopics are not provided during assay, the NDA EA compares the measured and AK-based values and derives technically appropriate isotopic values. If this process does not provide valid isotopic values, the drum is rejected. The report i ncluded default isotopic values for WG, default reactor-grade, mixed and 241 Am-enriched Pu, as well as for natural uranium (NU) and DU. None of this information was included in the AKSR, but i s apparently available in references and

literature. Examination of NDA data for both the S3 900 and S5400 drums from LBNL indicates that default isotopics were used for the S5400 drum No. NT041489A, and measured values were

used for S3900 drum No. NT080018R. Based on the abo ve information, development and implementation of the AK-NDA memorandum were adequa te.

ID-NTS-TTR-HET debris from the Tonopah Test Range/R oller Coaster Project stored at Nevada National Security Site (AKSR CCP-AK-INL-014, Revision 0)

John Kleckner prepared the AK-NDA memorandum that w as issued August 14, 2009. The document states, “[in] most cases experience has sh own that the isotopic codes MGA or FRAM will provide a reasonable estimate of the waste iso topic distribution.” However, in those instances when the measurement does not yield a rea sonable isotopic distribution, the NDA EA compares the measured and AK-based values and deriv es technically appropriate isotopic values. If this process does not provide isotopic values, t he drum is rejected. The report provides default isotopic values for WG Pu and DU, Tables 3 and 4, r espectively. The single drum in this waste stream did not require use of default isotopics. Ba sed on the information reviewed, development and implementation of the AK-NDA memorandum were ad equate.

Contact-Handled Waste Streams from the Accelerated Retrieval Project (AKSR CCP-AK-INL-001, Revision 9)

A single AK-NDA memorandum has been issued that app lies to all three ARP waste streams and is included with Attachment 7 of CCP-TP-005, Revisi on 18, prepared for each stream. The most recent memorandum is dated June 7, 2010 and does no t include reference to ARP-V, which was added in AKSR, Revision 9, dated September 8, 2010. It is assumed that the AK-NDA memorandum will eventually be updated to include AR P-V. The AK-NDA memorandum states that the soil, sludge, and debris waste streams are actually conglomerations of several waste streams mixed during retrieval, and it is not possi ble to predict a radiological distribution when the waste streams are expected to contain undetermi ned and varying amounts of the parent waste streams. Tables 1 and 2 in the AK-NDA memorandum pr esent the mass and activity fractions by target waste type, with overall waste radiological distribution provided in Table 3. This memorandum states that if NDA does not yield valid isotopic results, default isotopics based on RFP WG Pu, HEU, and DU will be used, as detailed in Tables 4 – 6; 242 Pu will be determined by correlation techniques and 234 U will be scaled to 235 U and/or 238 U, as appropriate.

As in the AKSR, Revision 9, the predicted radionucl ide distributions have not been corrected for decay or in-growth, and a footnote has been include d to bring this to the reader’s attention. EPA

5 MGA is Multi Group Analysis. FRAM is Fixed-energy Response function Analysis with Multiple efficienci es.29

raised this issue with INL-CCP, who responded that they did not want to correct all of the radionuclides for decay/in-growth and so were not c orrecting any of the radionuclides, and that it

did not matter because the measurements of record a re observed values from NDA. However,

there are times when NDA data are not usable and th e declared isotopics become part of the measurement of record. In such situations, 241 Am may be underreported. It is EPA’s position that

there is no need to correct all radionuclides in th e AK-NDA memorandum. However, quantification of the 10 WIPP-tracked radionuclides and their uncertainty is required and this

includes 241 Am. The calculation of 241 Am in-growth from its progenitor 241 Pu (half-life approximately 14.2 years) is relatively simple and can change significantly over the time frames

relevant to characterization of TRU waste for WIPP. EPA expects that the AK-NDA memorandum contain the most accurate information pr acticable regarding the 10 WIPP-tracked radionuclides. Accordingly, if information regardin g the in-growth of 241 Am is available for a specific group of wastes, waste containers or waste stream(s), it should be integrated in the AKNDA memorandum, as appropriate. EPA expects informa tion addressing the in-growth of 241 Am

to be included in the AK record.

No further response is required at this time. Revis ion of the AK-NDA memoranda applicable to the ID-SDA-SOIL, ID-SDA-SLUDGE, and ID-SDA-DEBRIS w aste streams, or preparation of new, separate memoranda, remains a T2 change.

Summary of Contact Handled Acceptable Knowledge Res ults

Acceptable Knowledge Findings or Concerns

The EPA Inspection Team did not identify any AK fin dings or concerns related to AK for CH wastes as a result of this continued compliance ins pection. Changes to Acceptable Knowledge Tiering

There are no changes to the T1 or T2 designations t o INL-CCP’s CH waste characterization programs as a result of this continued compliance i nspection.

Acceptable Knowledge Conclusions

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP demonstrated continued AK characterization complian ce for CH waste streams.

6.1.2 Remote-Handled Waste Streams

This report includes only the new information EPA e valuated for the RH waste streams approved as T1 changes in 2009 -2010. The review did not inc lude examination of AKSRs with respect to waste stream determination and other types of data, because EPA recently reviewed and approved this information as part of the T1 review process.30

Background Information

EPA’s INL-CCP continued compliance inspection scope included all RH streams approved since

2009. These waste streams included:

• ID-ANLE-S5000 [Argonne National Laboratory-East (AN LE 6 ), additional drums]

• ID-HFEF-S5400-RH [Hot Fuel Examination Facility (HF EF), Lots 1a and 1b

• ID-MFC-S5400-RH (MFC)

• IN-ID-NRF-153 [Naval Reactors Facility (NRF)]

• ID-INTEC-RH [Idaho Nuclear Technology and Engineeri ng Center (INTEC)]

• ID-RTC-S3000 [Test Reactor Area (TRA)]

T1 requests for the NRF and TRA waste streams were recently approved by EPA and the ANLE waste stream change involved only a few drums, so t hese waste streams were not included in EPA’s continued compliance inspection. The continued compliance inspection focused on the MFC, HFEF, and INTEC RH waste streams.

Waste Characterization Element Description

Because many elements related to these waste stream s were previously covered by EPA’s T1 approvals, EPA's continued compliance inspection ad dressed the following:

• WSPF and Characterization Reconciliation Report (CR R) adequacy

• New NCRs and AK DRs

• AK accuracy

• AK data traceability related to characterization/co nfirmation activities

• Adequacy of T1 review result requirements, includin g revision of documents to address

T1 review results

Documents, Waste Containers, and Batch Data Reports Reviewed

Several attachments, source documents, required for ms, and other data were provided to EPA as part of the continued compliance inspection. The li sting of RH AK source documents examined is presented in Attachment C.2. BDRs examined as pa rt of the RH continued compliance inspection are presented below. All available BDRs for the HFEF waste stream were provided to EPA, but the three presented below include two of t he most recent drums emplaced in the WIPP facility (October 1, 2010). Table 6 below lists the BDRs that were provided for the HFEF drums as well as the two INTEC and eight MFC waste drums.

Table 6. Remote-Handled Batch Data Reports Examined

Waste Stream Drum Number NDE BDR Number DTC BDR Number

ID-INTEC-RH IDIC000000460 RHINLVE090001 INLRHDTC090 04

ID-INTEC-RH IDIC000000427 RHINLVE090001 INLRHDTC100 02

6 ANLE is now called simply ANL but many existing re cord use the old name.31 Table 6. Remote-Handled Batch Data Reports Examined

Waste Stream Drum Number NDE BDR Number DTC BDR Number

ID-HFEF-S5400-RH SN152A

SN152B INLRHRTR10009 INLRHDTC10012

ID-HFEF-S5400-RH IDAWANL780204A INLRHRTR09006 INLRH DTC09006

ID-MFC-S5400-RH IDAWANL880065A

DAWANL880065B

IDAWANL880068A

IDAWANL880068B

IDAWANL880134A

IDAWANL880134B INLRHRTR09009 INLRHDTC09009

ID-MFC-S5400-RH IDAWANL880064A

IDAWANL880064B RHINLVE090003 INLRHDTC09009

Technical Evaluation

(1) The Waste Stream Profile Form and related chang e requests, as well as new/updated Characterization Reconciliation Reports, were evalu ated and found to be adequate.

Remote-Handled Waste Stream ID-INTEC-RH

The WSPF provided to EPA during this inspection was approved on September 15, 2010. The waste stream is described as debris that may includ e combustibles and noncombustibles, as well as solidified sludge of acid-dissolved fuel, absorb ed with diatomaceous earth. The WSPF states that the waste stream consists of two 30-gallon lea d-lined drums, Nos. IDIC000000460 and

IDIC000000427. The WSPF includes the CRR for the wa ste stream. No change requests were provided for the waste stream, and the drums have b een emplaced in the WIPP.

Remote-Handled Waste Stream ID-HFEF-S5400-RH

The WSPF provided to EPA during the inspection was approved on February 10, 2010. This WSPF said the waste stream was composed of organic and inorganic debris derived through the examination of irradiated fuel pins. The waste stre am consists of 91 waste canisters, and the

WDS indicates about 75 individual drums or containe rs have been emplaced in the WIPP since the waste was first shipped on March 11, 2010. No c hange requests were provided for the waste

stream. The CRR attached to the WSPF addressed nine of the initial drums included in the shipment; no additional CRRs were provided to EPA.

Remote-Handled Waste Stream ID-MFC-S5400-RH

The WSPF provided to EPA during the inspection was approved on June 24, 2010. The waste stream is described as glassware, paper, poly, and miscellaneous hardware generated during analytical chemistry laboratory hot cell operations . The WSPF states that the waste stream consists of eight 55-gallon drums packaged into thr ee RH canisters. The WSPF includes the CRR for the waste stream. No change requests were p rovided for the waste stream, and the drums have been emplaced in the WIPP.32

Based on the information above, INL-CCP continues t o adequately prepare WSPFs and related

attachments.

(2) New Non Conformance Reports and AK discrepancy resolutions were reviewed and found to be adequate.

Remote-Handled Waste Stream ID-INTEC-RH

DR001, dated October 13, 2009, was provided to EPA as part of the original T1 review. DR002

was listed on the new AKSR reference list and altho ugh RCRA-related, was provided to EPA as part of this inspection. No new DRs relevant to EPA ’s characterization program were generated. EPA approved the T1 request for this waste stream i n August 2010. NCR Nos. NCR-RHINL0501-10, NCR-RHINL-D502-10, NCR-RHINL-0504-09, NCR- RHINL-0507-09, and NCRRHINL-0512-09 were prepared prior to EPA’s approval . EPA reviewed the NCR process as part

of the T1 review and no new NCRs were issued for th is waste stream after EPA approval.

Remote-Handled Waste Stream ID-HFEF-S5400-RH

DR003, dated August 27, 2009, was provided to EPA a s part of the original T1 review. DR004 is a new DR generated post-EPA approval that addresses liquids in HFEF cans and was provided to EPA upon request. No other DRs were provided. EPA a pproved the T1 request for Lot 1a in February 2010 and Lot 1b in August 2010. INL-CCP pr ovided four example NCRs pertaining to this waste stream that were issued after EPA’s appr oval of Lot 1a:

• NCR-RHINL-0500-10, issued February 10, 2010, indica ted that the surface dose rate for Drum No. IDAWANL870105A measured 70 millirem per ho ur (mrem/hr), not the required >200 mrem/hr. The disposition for this dru m was to return it to the host site.

• NCR-RHINL-0507-10, issued May 25, 2010, dealt with addition of containers to the AK tracking spreadsheet. The information was added to the AK tracking spreadsheet, and no final disposition was identified.

• NCR-RHINL-0514-10, issued October 18, 2010, dealt w ith the identification of negative container weight on a waste conversion record. The final disposition was not identified, although the issue did not impact AK.

• NCR-RHINL-0515-10, issued November 2, 2010, stated that drum Nos. N154B, N153A and SN151A did not meet the decay heat limits speci fied in approved RH-TRUCON codes. The final disposition was not identified, al though the issue did not impact AK.

Remote-Handled Waste Stream ID-MFC-S5400-RH

DR002, dated September 23, 2008, was provided to EP A as part of the original T1 review. DR003 is a new DR generated post-EPA approval that addresses the size of the waste-containing paint cans within the eight drums and was provided to EPA upon request. No other DRs relevant to the MFC waste stream have been generated. EPA ap proved the T1 request for this waste stream in June 2010. INL-CCP had not prepared any N CRs pertaining to this waste stream prior to EPA approval and had issued one NCR pertaining t o this waste stream after EPA’s approval.33

NCR-RHINL-0509-10, issued July 20, 2010, indicated that the ITR did not properly review the Audio/Video for drum No. IDAWANL880065A. The dispos ition was to rework the RTR BDR

and resubmit the document to records.

Based on the information presented above, EPA concl udes that INL-CCP continues to prepare DRs and NCRs as required.

(3) Acceptable Knowledge accuracy was reviewed and found to be adequate.

Remote-Handled Waste Stream ID-INTEC-RH

The AK accuracy report was approved and finalized o n November 5, 2010. While the subject of the report was the INL Waste Stream ID-INTEC-RH, Lo t 1, the text addressed Waste Stream SR-BCLPD.004.002. INL-CCP agreed that the report wa s in error and indicated that a revision was in process. Notification of availability of a r evised final INTEC AK accuracy report remains a T2 change.

Remote-Handled Waste Stream ID-HFEF-S5400-RH

A draft AK accuracy report, dated October 12, 2009, was provided to EPA that indicated Lots 1- 9 exhibited 100% AK accuracy, because no waste was reassigned to a different SCG or waste stream, and the radiological parameters were accura te with respect to AK. Verification of accuracy was accomplished through achievement of AK -based data quality objectives (DQOs). Although not explicitly stated, presentation of the DQOs in this manner shows that the SCG assignment was not modified, the drums were not pla ced in a different waste stream, and some of the general radiological parameters (i.e., TRU and RH determination) were met through implementation of the WCPIP and comparison to the A K Record. It is expected that the final report will include all lots characterized through 2010. Notification of availability of a final AK accuracy report for this waste stream remains a T2 change.

Remote-Handled Waste Stream ID-MFC-S5400-RH

EPA evaluated a draft AK accuracy report, dated Apr il 15, 2010 and found it to be adequate during the T1 review. The AK accuracy report indica ted that all eight drums exhibited 100% AK accuracy, because no waste was reassigned to a diff erent SCG or waste stream, and the radiological parameters were accurate with respect to AK. A final AK accuracy report is not yet available. Notification of availability of the fina l MFC AK Accuracy report remains a T2 change.

(4) Acceptable Knowledge data traceability as it re lated to characterization/confirmation activities was reviewed and found to be adequate.

The same traceability information was provided for the INTEC, HFEF, and MFC waste streams, so all were evaluated together. Data were provided to evaluate tracking of information for all three wastes streams, from the NDA/NDE phase throug h shipment, to emplacement in the WIPP. INL-CCP provided the following documents for each w aste stream:34

• CCP-TP-005, Revision 18, Attachment 8, which is a d rum list showing drum status as of the date of list generation (i.e., repackaging stat us). This attachment is not necessarily a complete list of all containers in the waste stream

.

o INTEC : November 12, 2009

o HFEF : November 12, 2009

o MFC : February 2, 2010

• The AK tracking spreadsheet was also provided, whic h is a drum list that is current as of the date of report generation (September 27, 2010). There is one AK tracking spreadsheet for each site, so the same document was provided in reference to each of the three

evaluated here.

• Several BDRs were provided (DTC, RTR, and VE); a su bset of these BDRs is included

in the WSPF CRR.

• INL-CCP provided a WDS spreadsheet that includes sh ipment, emplacement and other data. Once the WSPF is approved and shipment begins , INL-CCP tracks and has access

to WDS information.

• PTS screen shots show tracking data maintained by I NL-CCP, including NCR

identification and status.

These mechanisms show that drum data are recorded t hroughout the characterization and emplacement process.

To verify traceability of data, drum Nos. IDWWAL780 204A and IDAWANL880068A were tracked through the various characterization data s heets, databases, and ultimate emplacement of the waste in WIPP to verify that the same informati on was transferred throughout the process.

Data examined included BDRs and WDS and PTS informa tion; data in these examples were found to be traceable. In summary, the information provided shows that INL-CCP has access to information about each container throughout the cha racterization, shipment, and emplacement processes, and this traceability is adequate.

(5) Compliance with tiering requirements, including revision of documents to address Tier 1 review results, was evaluated and found to be adequ ate.

EPA examined key documents identified in EPA’s T1 a nd T2 requirements to determine whether

the most recent revision of these documents is avai lable, whether EPA was properly notified of the documents’ availability, and to determine the s tatus of document reviews and revisions. EPA examined the tiering elements and associated docume nts and activities as a status check to determine whether the ongoing characterization proc ess incorporated these elements. The results of this examination are presented in Table 7 below.

Based on the information in Table 7 below, EPA dete rmined that, for the most part, data are available to evaluate the T1 compliance issues; the HFEF waste stream’s AKSR does not yet include the changes necessary to address issues ide ntified during EPA’s T1 evaluation. EPA was also provided updated information about the documen ts associated with each of the T2 elements.35

EPA determined that the quarterly T2 notification r eports continue to include revised or newly issued documents as required under 40 CFR 194.8.36Table 7. Summary of Compliance with Tiering RequirementsTierTiering Requirements1INTECHFEFMFCT1 Addition of containers to approved wastestreams if new or different radionuclide-scalingfactors or a different radiologicalcharacterization process are requiredThe INTEC waste stream is of finitesize and has been emplaced inWIPP, so no addition of containersis anticipated.INL-CCP indicated that new “lots”may be added to the waste stream inthe future that require different scalingfactors, but CCP-AK-INL-581,Revision 1 was updated to include theLot 1b scaling factors, but noadditional new scaling factors.The MFC waste stream is of finitesize and has been emplaced inWIPP, so no addition of containersis anticipated.T1 Any new RH waste streams not approved todateEPA was not informed of new RH waste streams as part of the inspection, and understands that these requests may bein forthcoming T1 change requests.T1 Substantive modification(s) that have thepotential to affect the characterization process:CCP-AK-INL-500, CCP-AK-INL-501, orCCP-AK-INL-502The INTEC waste stream is of finitesize and has been emplaced inWIPP, so no substantivemodifications are expected.Substantive modifications may occurin the future; however, the most recentversion of these documents wasprovided during this inspection andsuch modifications have not beenmade.The MFC waste stream is of finitesize and has been emplaced inWIPP, so no modifications affectingthe characterization of this wastestream are expected. The 580document has been modified toinclude an additional waste streamthat may be the subject of aforthcoming T1 change request.T1 Load management for any RH waste stream EPA didnot find that load management was being performed for these waste streams.T2 Notification to EPA when updates to AKSummary Reports (AKSRs), RadiologicalCharacterization Reports, and ConfirmationTest Plans (e.g., CCP-AK-INL-500, CCP-AKINL-501, and CCP-AK-INL-502) are approvedby CBFOThe most updated versions of thesedocuments were provided to EPAduring the inspection. CCP-AKINL-550, Revision 1 was approvedby CBFO on March 10, 2010, andEPA was notified of this change viathe CBFO FY2010 2ndquarter T2reporting. This revision includes thechanges necessary to addressconcerns identified during EPA’s T1evaluation.The most updated versions of thesedocuments were provided to EPAduring the inspection. EPA wasnotified of the availability of CCPAK-INL-580, Revision 2, CCP-AKINL-581, Revision 1, and CCP-AKINL-582, Revision 1 via the CBFOFY2010 3rdquarter T2 reporting.Revision 2 of the AKSR does notinclude the Lot 1b freeze file changesgenerated as a result of EPA’s Tieringreview. EPA expects that Revision 3will address these changes.The most updated versions of thesedocuments were provided to EPAduring the inspection. CCP-AKINL-540, Revision 2 was approvedby CBFO on November 8, 2010.This revision includes the changesnecessary to address concernsidentified during EPA’s T1evaluation. EPA expects that officialnotification of this revision will bemade via the CBFO FY2011 1stquarter T2 reporting.T2 Notification to EPA when changes to AKdocumentation as a result of WasteCharacterization Program Implementation Plan(WCPIP) revisions have been made [e.g.,Characterization ReconciliationReports (CRRs)]The new WCPIP was only recently approved, so EPA determined that none of the expected changes todocumentation (e.g., CCP-TP-005) would be availableat this inspection.37Table 7. Summary of Compliance with Tiering RequirementsTierTiering Requirements1INTECHFEFMFCT2 Notification to EPA when a Correlation orSurrogate Summary Form is completed foreach of the RH containers in this waste streamidentified as contact-handled (CH), based uponmeasured dose rates that presentnondestructive assay (NDA) results for assayedcontainersCSSFs were not provided to EPAduring the inspection, so it isassumed that none are available.CSSFs were not provided to EPAduring the inspection, so it is assumedthat none are available.CSSFs were not provided to EPAduring the inspection, so it isassumed that none are available.T2 Notification to EPA once waste stream datapackage for debris waste stream and anymodifications to the Waste Stream ProfileForm (WSPF), including the CRR and AKSR,are completedSee Item (1), above. Notification ofthe availability of the final WSPFwas provided to EPA via the CBFOFY2010 4thquarter T2 reporting.See Item (1), above. Notification ofthe availability of the final WSPF wasprovided to EPA via the CBFOFY2010 2ndquarter T2 reporting.See Item (1), above. Notification ofthe availability of the final WSPFwas provided to EPA via the CBFOFY2010 4thquarter T2 reporting.T2 Notification to EPA that the final dose-to-curie(DTC) determination is complete for RHcontainers 728 through 737, as identified inAK Reference P030The requirement is not applicable to these waste streams. This information was not provided during theinspection,and EPA expects it would be included, as available,in T2 request quarterly responses.T2 AK accuracy reports (prepared annually, at aminimum)See Item (3), above. The final AKaccuracy report is dated November5, 2010, and therefore EPA expectsthat notification of availabilityshould occur via the CBFO FY20111stquarter T2 reporting.See Item (3), above. EPA has notreceived notification of the availabilityof an AK accuracy report.See Item (3), above. EPA has notreceived notification of theavailability of a final AK accuracyreport.T2 Notification to EPA when additional containersare added to RH TRU debris or sludge wastestreams that have been approved to date andthe containers were characterized using thesame radionuclide-scaling factorsThe INTEC waste stream is of finitesize and has been emplaced inWIPP, so no addition of containersis anticipated.The HFEF waste stream, as approvedby EPA, is expected to add containersas waste is generated. EPA expectsthat notification will be provided asoutlined in the HFEF Lot 1b T1approval report.The MFC waste stream is of finitesize and has been emplaced inWIPP, so no addition of containersis anticipated.T2 Notification to EPA of availability of a revisedAKSR and source documents supporting theaddition of containers to the approved wastestreamsThe INTEC waste stream is of finitesize and has been emplaced inWIPP, so no addition of containersis anticipated.See Item (1) above. EPA requestedcopies of new source documents andreceived that information during thecontinued compliance inspection.The MFC waste stream is of finitesize and has been emplaced inWIPP, so no addition of containersis anticipated.38Table 7. Summary of Compliance with Tiering RequirementsTierTiering Requirements1INTECHFEFMFCT2 Notification to EPA when Attachment 4 ofCCP-TP-005 is generated to reflect the updatedAKSR Source Document Reference ListA revised Attachment 4 wasprovided. EPA did not receivenotification of the availability of therevised Attachment 4; however, thisT2 requirement was put in placeafter the most recent AKSR revisionand it is assumed that Attachment 4is only updated upon CBFO’sapproval of an AKSR revision.A revised Attachment 4 was provided.EPA did not receive notification of theavailability of the revised Attachment4; however, this T2 requirement wasput in place after the most recentAKSR revision and it is assumed thatAttachment 4 is only updated uponCBFO’s approval of an AKSRrevision.A revised Attachment 4 wasprovided. EPA did not receivenotification of the availability of therevised Attachment 4; however, it isassumed that Attachment 4 is onlyupdated upon CBFO’s approval ofan AKSR revision, notification ofwhich is expected via the CBFOFY2011 1stquarter T2 reporting.Therefore, EPA expects thatnotification of availability of therevised Attachment 4 will also takeplace via the CBFO FY2011 1stquarter T2 reporting.1These are the tiering requirements as published inthe most recent INL-CCP T1 approval report (approval of TRA sludge waste, A-98-49, II-A4-137, November 1, 2010).39

Summary of Remote Handled Acceptable Knowledge Resu lts

Acceptable Knowledge Findings or Concerns

The EPA Inspection Team did not identify any AK fin dings or concerns as a result of the RH portion of the continued compliance inspection.

Changes to Acceptable Knowledge Tiering

There are no changes to the T1 or T2 designations f or INL-CCP’s RH waste characterization program as a result of this continued compliance in spection.

Acceptable Knowledge Conclusions

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP demonstrated continued AK characterization complian ce for RH waste streams.

6.1.3 Summary of Acceptable Knowledge Results

Acceptable Knowledge Findings or Concerns

The EPA Inspection Team did not identify any AK fin dings or concerns for INL-CCP’s CH or RH waste characterization programs as a result of t his continued compliance inspection.

Changes to Acceptable Knowledge Tiering

There are no changes to the T1 or T2 designations t o INL-CCP’s CH or RH waste characterization programs as a result of this conti nued compliance inspection.

Acceptable Knowledge Conclusions

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP demonstrated continued waste characterization compl iance for all evaluated CH and RH waste

streams.

6.2 Nondestructive Assay

EPA had approved the SuperHENC and the WAGS NDA sys tems initially during the baseline inspection and two subsequent continued compliance inspections in 2008 and 2009. The systems’ abilities to perform the required analyses had been demonstrated during the baseline and confirmed in the two continued compliance inspe ctions. Accordingly, this inspection focused on the following:

• Confirming that the design and technical capabiliti es of both NDA systems’ hardware and software had not changed since EPA’s last inspe ction

• Adequacy of the current revisions of the INL-CCP ND A procedures and documents40

• Operational and maintenance history of the NDA syst ems since the last EPA inspection

• Knowledge, understanding and training status of INL -CCP NDA personnel

The documents that EPA examined in assessing the WA GS and SuperHENC systems during this inspection are listed in Appendix C.3.

6.2.1 Technical Evaluation: Waste Assay Gamma Spectromete r

The following aspects of the WAGS were evaluated du ring this inspection:

(1) The Waste Assay Gamma Spectrometer Nondestructive A ssay system is the same system that was approved previously.

The WAGS system is located at INL in the facility f ormerly called the SWEPP, 7 Building WMF-610. The EPA inspection team verified that ther e have been no substantive hardware or software changes to this system except for the dete ctor replacement that is discussed under Item (3) below.

(2) The design and operational range of the Waste Assay Gamma Spectrometer were assessed and were found to be unchanged from the la st inspection and were adequate for the wastes currently being assayed.

The WAGS assays retrievably stored (legacy) wastes and newly generated wastes from the ARP at INL. ARP wastes include sludge, debris and soils , most of which originated at RFP and are primarily WG Pu covered under AK Memorandum 19. Add itional wastes are from the SQS program and include wastes from LLNL, which are not typically WG Pu wastes. These wastes contain fuel-grade, reactor-grade and mixed isotopi cs-grade Pu, as documented in AK Memorandum 18. Between January 2010 and November 16 , 2010, the WAGS assayed 1,617 drums that were compiled in 191 BDRs. The EPA Inspe ctors observed the assay of drum No. 10348288, a legacy waste sludge that had a density of 0.0920 kilograms/liter and approximately 0.5 g 239 Pu upon assay. All daily performance measurements w ere observed, appropriately recorded and were in control. Specifically, backgro und, daily performance check, Full Width at Half Maximum (FWHM), energy calibration (gain) and barium-133 ( 133 Ba) transmission source checks were evaluated, as evidenced in the WAGS dai ly operational logbook and BDRs. Warning and Control Limits [2 and 3 sigma ( σ ) limits] for all parameters had been established and documented, as appropriate, and background [~40 counts per second (cps), full spectrum], FWHM and gain were controlled by boundary limits. D ecay correction of the 133 Ba transmission source was performed in the software. Typical assay times for debris drums were ~32 minutes and ~26 minutes for sludge drums. EPA Inspection per sonnel observed that WAGS personnel had available and were using the current revisions of the WAGS operating procedure. All operational aspects of the WAGS operation were acce ptable.

7 SWEPP is the Stored Waste Examination Pilot Plant.41

(3) System calibration and calibration confirmation of the Waste Assay Gamma Spectrometer Nondestructive Assay system had been p erformed and documented as required.

The EPA inspection team verified that the system’s original calibration was unchanged. One calibration verification had been performed since t he last EPA inspection, when a gamma detector was replaced. This was documented in CCP-I NL-WAGS-10-005; all aspects of the calibration verification were technically acceptabl e and appropriately documented.

(4) The total measurement uncertainty of assays perform ed on the Waste Assay Gamma Spectrometer Nondestructive Assay system had been d etermined and documented, as required.

CCP-INL-WAGS-002, Total Measurement Uncertainty for the WAGS System adequately documents all pertinent aspects of the system’s tot al measurement uncertainty (TMU). The EPA inspection team verified that this document was unc hanged from EPA’s last inspection.

(5) The lower limit of detection, including the minimum detectable concentration of the Waste Assay Gamma Spectrometer, had been determined and documented, as required.

CCP-INL-WAGS-001, Revision 1, April 2008, adequatel y documents the technical basis for the system’s lower limit of detection (LLD), including reporting thresholds for specific nonmeasured radionuclides 242 Pu and 90 Sr. The EPA inspection team verified that this docu ment was unchanged from EPA’s last inspection.

(6) The Waste Assay Gamma Spectrometer had successfully participated in Drum Cycle 17A and Box Cycle 9A of the CBFO-sponsored Performance Demonstration Program (PDP), as required.

(7) Personnel training was assessed and found to be ade quate.

All NDA personnel associated with the calibration, operation and data review and approval of the WAGS had current training in the applicable are as as evidenced by the List of Qualified Individuals (LOQI) provided during the inspection.

(8) EPA replicate testing of the Waste Assay Gamma Spec trometer unit was performed and evaluated, and was found to comply with the criteri a for the Environmental Protection Agency Replicate Testing Protocol.

The purpose of the replicate testing performed as p art of this inspection is to provide EPA with an independent means to verify that the WAGS can pr ovide reproducible results for the determination of the quantity of 10 WIPP-tracked ra dionuclides ( 241 Am, 137 Cs, 238 Pu, 239 Pu,

240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U) and the TRU alpha concentration. 8 This is accomplished

8 Revision 2 of the EPA Replicate Testing Protocol p rovides the details of the replicate testing assay protocol

and data evaluation.42

by the WAGS reassaying drums it previously measured to demonstrate the system’s ability to do the following:

• Produce results consistent with the reported TMU by comparing the sample standard deviation for a number of replicate measurements ta ken over several hours or days to the reported TMU

• Provide reproducible results over longer periods of time, such as weeks or months, by comparing the results of the replicate measurement( s) to the original reported values.

As with all statistical evaluations, there are limi tations inherent in this protocol. The usefulness of the results depends in large part on the degree to which the conditions encountered are consistent with the assumptions upon which the test s are predicated. EPA’s experience to date

indicates that containers chosen at random do not a lways provide information best suited for the application of these statistical protocols. For exa mple:

• An NDA system may have been recalibrated in the tim e period between the original assay and the reassay performed during an inspectio n, and the new calibration may have different values for some of the calibration algori thm’s terms.

• The containers chosen at random for replicate analy sis may lack sufficient nuclear material content to provide useable data for some o r all of the WIPP-tracked

radionuclides.

• High precision for the five replicate assays may yi eld an average value that differs slightly from the original assay value, but produce s results that the statistical analysis

indicates are Significant

or Highly Significant . However, these differences may be small

variations that are more a function of the statisti cal protocols and do not indicate true measurement trends or problems, as discussed below.

• Since some radionuclides are quantified based on th e measurement of another radionuclide, a Significant or Highly Significant

indicator for one measured entity will be reflected in the other three, indicating a larger p otential measurement trend or problem than actually exists. Examples include: values for 238 Pu and 240 Pu, which are derived by applying an isotopic ratio to a measured 239 Pu value; and 137 Cs and 90 Sr that are quantified based on a directly measured 241 Am value, an inferred 137 Cs value, and a scaling factor for 90 Sr, as discussed below.

It is important to keep these in mind when evaluati ng replicate data and to realize that Significant

or Highly Significant

results may not, in fact, be representative of tru e measurement issues, as

discussed below for drum No. ARP22225.

As part of this inspection, EPA requested that INL- CCP reassay two drums that EPA randomly selected from a list of drums previously assayed on the WAGS. Drum Nos. ARP21969, and ARP22225 were reassayed five times and the results were compared to the original assay data. Two statistical tests, a chi-squared (χ 2 ) test and a t

test, were performed. Data and results of the statistical analysis are included in Attachments B. 1and B.2. For drum Nos. ARP21969 and ARP22225, the χ 2 test showed that the observed variances in the rep licate measurements are less43

than or equal to the reported uncertainties within the statistical limits of the test. For drum No. ARP21969, the t

test showed no statistically significant differenc es between the original assay values and the average of the five replicate measur ements.

The t test for drum No. ARP22225 showed a statistically Highly Significant difference between the original assay value and the average of the fiv e replicate measurements for 238 Pu, 240 Pu and

242 Pu. The test also indentified a statistically Significant difference between the original assay value and the average of the five replicate measure ments for 237 Np. This indicates that the variances in the replicate measurements for these i tems were greater than the reported

uncertainties for all values relative to the limits of the test. The 242 Pu values that were found to be Highly Significant , was expected based on the manner in which this ra dionuclide is measured. There are several possible reasons for the Highly Significant differences for 238 Pu and 240 Pu replicate versus original—actual changes in the phy sical configuration of the drum’s contents due to movement or settling; fluctuations in the me asurement system’s background; temporal factors such as radioactive growth or decay; or, ac tual changes in the measurement system, the aspect that this test is designed to query. Althoug h the software identified these variances as Highly Significant , this does not necessarily indicate a measurement issue that warrants additional attention at this time. Further inspecti on of the five replicate measurements found a small standard deviation in value. The original mea surement values were sufficiently similar to replicates that despite its classification as Highly Significant by the t test, there is no reason to question the instrument’s performance.

6.2.2 Technical Evaluation: Super High Efficiency Neutron Counter

The following aspects of the SuperHENC were evaluat ed during this inspection:

(1) The Super High Efficiency Neutron Counter Nondestru ctive Assay system is the same system that was approved previously.

The SuperHENC system is located at INL in the facil ity formerly called the SWEPP, Building WMF-610, South Bay, and is officially designated as NDA SHENC-01. The EPA inspection

team verified that there have been no substantive h ardware or software changes to this system since the last EPA inspection.

(2) The design and operational range of the Super High Efficiency Neutron Counter were assessed and were found to be unchanged from the la st inspection and were adequate for the wastes currently being assayed.

The SuperHENC assays a variety of configurations: 5 5-gallon drums of dry combustibles; SWBs containing debris; 100-gallon drums containing puck s 9 ; one SWB containing two puck drums; and, one SWB containing four 55-gallon drums of slu dge. Two interfering matrix baseline tests were performed and documented for the SuperHENC, on e for a 55-gallon drum of dry combustibles and one for 2-pucks of light metals in an SWB. Approved waste streams include BN550 (from AMWTP), as documented in RPT-TRUW-07, t he AK document for

9 Pucks are 55-gallon drums of TRU waste that have been co mpacted into smaller disks by crushing, the pucks are then over-packed in 100-gallon drums which are referred to as pucked drums

.44

supercompacted waste from RFETS and DOE’s Mound Sit e, consisting of mixtures of 12% and

23% 240 Pu wastes. The EPA Inspectors observed that daily p erformance measurements were appropriately recorded and were in control. Specifi cally, neutron and gamma backgrounds, daily gamma source check, and californium-252 normalizati ons were performed, as evidenced in the SuperHENC daily operational logbook and BDR No. INN DA BO9016. Warning and Control Limits (2 and 3 σ limits) for all parameters had been established an d documented, as appropriate. Background limits were established as an upper limi t, i.e., three times the average gamma and neutron backgrounds observed during the system’s in itial calibration. All operational aspects of the SuperHENC were acceptable.

(3) System calibration and calibration confirmation of the Super High Efficiency Neutron Counter had been performed and documented as requir ed.

The EPA inspection team verified that the system’s original calibrations for all previously approved assay configurations were unchanged. No ca libration verifications had been performed since the last EPA inspection.

(4) The total measurement uncertainty of assays perform ed on the Super High Efficiency Neutron Counter had been determined and documented, as required.

The EPA inspection team verified that the system’s original determination of TMU for all previously approved assay configurations were uncha nged since the last EPA inspection.

(5) The lower limit of detection, including the minimum detectable concentration of the Super High Efficiency Neutron Counter, had been det ermined and documented, as required.

The EPA inspection team verified that the system’s original determination of LLDs for all previously approved assay configurations were uncha nged since the last EPA inspection.

(6) The Super High Efficiency Neutron Counter had succe ssfully participated in Drum Cycle 17A (combustibles and metals matrices) and Box Cycl e 9A (combustibles and metals matrices) of the CBFO-sponsored PDP, as required. A dditionally, INL-CCP submitted data for Box Cycle 10A on October 10, 2010, but had not received results at the time of the inspection.

(7) Personnel training was assessed and found to be ade quate.

All NDA personnel associated with the calibration, operation and data review and approval of the SuperHENC had current training in the applicabl e areas as evidenced by the LOQI provided during the inspection.

(8) EPA replicate testing of the Super High Efficiency Neutron Counter was performed and evaluated, and was found to comply with the criteri a for the Environmental Protection Agency Replicate Testing Protocol.45

The purpose of the replicate testing performed as p art of this inspection is to provide EPA with an independent means to verify that the SuperHENC c an provide reproducible results for the determination of the quantity of 10 WIPP-tracked ra dionuclides ( 241 Am, 137 Cs, 238 Pu, 239 Pu,

240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U) and the TRU alpha concentration. 10 This is accomplished by the SuperHENC reassaying drums it previously mea sured to demonstrate the system’s ability to provide the following:

• Results consistent with the reported TMU by compari ng the sample standard deviation for a number of replicate measurements taken over s everal hours or days to the reported

TMU

• Reproducible results over longer periods of time, s uch as weeks or months, by comparing the results of the replicate measurement(s) to the original reported values

EPA requested that INL-CCP reassay one waste drum t hat EPA randomly selected from a list of drums previously assayed on the SuperHENC. EPA chos e Drum No. BN10381564. The previously assayed drum was reassayed five times on the SuperHENC for this inspection. Two statistical tests, χ 2 test and a t test, were performed on the replicate analyses of t he drum. Analytical data for each assay event and results of the statistical analysis are included in

Attachments B.3

For both drums, the t

test showed no statistically significant differenc es between the original measurement assay value and the average of the five replicate measurements for all measurement parameters. The χ 2 test for these drums showed that the observed vari ances in the replicate measurements were less than or equal to the reporte d uncertainties for all values within the

statistical limits of the test. There are no outsta nding issues with either statistical test for this

drum.

6.2.3 Summary of Nondestructive Assay Results

Summary of Nondestructive Assay Findings and Concer ns

The EPA inspection team did not identify any findin gs or concerns related to the WAGS or SuperHENC NDA systems during this continued complia nce inspection.

Changes to Nondestructive Assay Tiering

There are no changes to the T1 or T2 designations f or NDA as a result of this continued compliance inspection.

Nondestructive Assay Conclusion

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP demonstrated continued NDA compliance for all evalu ated systems.

10 Revision 2 of the EPA Replicate Testing Protocol p rovides the details of the replicate testing assay protocol

and data evaluation.46

6.3 Real-Time Radiography

EPA evaluated INL-CCP’s continued compliance with E PA-approved RTR procedures for retrievably stored (legacy) CH waste and found comp liance to be adequate.

Technical Evaluation

EPA interviewed operators/ITRs and reviewed BDRs an d training records to verify ongoing RTR operations and training.

Operations were verified by review of BDR Nos. INRT R51000768, INRTR5100070, and INRTR5100076, generated in October and November of 2010 for CH drums. All BDRs contained an acceptable Measurement Control Report and a CCP Attachment 2, Radiography Data Sheet, had been completed for each drum. All a ttachments had been signed as required by procedure CCP-TP-053, Standard RTR Inspection Proce dure. Required quality control (QC) samples, Independent Observation and Replicate Scan , had been successfully completed and included in each BDR. Correct generation, recording and processing of NCRs were investigated by reviewing the following NCRs:

• NCR-INL-0661-10, NCR-INL-0662-10 (BDR No. INRTR5100 068)

• NCR-INL-0665-10, NCR-INL-0666-10 (BDR No. INRTR5100 070)

• NCR-INL-0677-10, NCR-INL-0678-10, NCR-INL-0550-10 ( BDR No. INRTR5100076)

BDR Nos. INRTR5100068 and INRTR5100070 had been rev iewed at both data generation (ITR) and project level (SPM). At the time of the o nsite inspection, INRTR5100076 had been reviewed at the ITR level only.

EPA reviewed the written and audio/visual record fo r drum No.10229559, which contained a large amount of liquid (17 pints). The operator res ponsible for this examination was interviewed to determine how the volume of this liquid, and tha t in other drums, was calculated. The information received from a second operator intervi ewed was different than that from the first, and EPA generated Concern INL-CCP-CH-RTR-10-01CR, R evision 1 to address this issue. The concern was discussed with INL-CCP RTR personnel an d is summarized below.

EPA Inspection Issue Tracking Form, Concern No. INL -CCP-CH-RTR-10-01CR,

Revision 1: There were two aspects to this concern, as follows :

• RTR operators that EPA interviewed did not describe a consistent method of volume calculation. For example, one operator always used a rectangular formula and another tried to use the closest standard shape formula. EP A is concerned that use of calculation formulae has the potential for inconsistent reporti ng of liquid volumes.

• RTR operators stated that they have not been provid ed any guidance for rounding and number of significant figures for reporting calcula ted liquid volumes.47

Resolution: EPA has determined that this method of estimating liquid contents of containers was implemented solely to comply with recent hazardous waste permit requirements. Continued use of this method does not adversely affect compliance with EPA requirements to reasonably estimate the quantity of liquid emplaced in the WIP P repository.

Status of Concern: EPA considers this issue closed.

EPA inspectors interviewed RTR operators/ITRs and r eviewed records to verify ongoing training and expertise. INL-CCP contracts with VJ Technologi es to provide training, including calculation of volumes, to RTR operators for CH was te. Personnel performing RH RTR are employed by CH2M-WG Idaho, LLC (CWI) but INL-CCP pr ovides oversight for the operations and examinations. CWI employees perform test drum e xaminations, which are scored by INLCCP personnel and are subject to CCP training requi rements. Operators were able to describe how data sheets are completed and how NCRs are init iated. Waste Stream AMWTP ID-RFS3114 was being processed by INL-CCP at the time of the on-site inspection, which does contain free liquid. The free liquid is considered as PCB ( polychlorinated biphenyl) liquid and these

drums are returned to the Advanced Mixed Waste Trea tment Project for reprocessing.

Test Drum records were reviewed and found to be com plete. Operators are required to successfully examine a test drum every six months t o remain qualified. INL-CCP has developed separate test drums for CH and RH wastes and for ea ch summary category group. EPA did not identify any concerns with regard to tr aining of RTR operators.

Summary of Real-Time Radiography Findings and Conce rns

The EPA inspection team did not identify any findin gs and did identify one concern related to RTR as performed by INL-CCP described above (see At tachment A for a copy of this concern) during this continued compliance inspection.

Changes to Real-Time Radiography Tiering

There are no changes to the T1 or T2 designations t o RTR as a result of this continued compliance inspection.

Real-Time Radiography Conclusion

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP demonstrated continued RTR compliance.

6.4 Visual Examination

EPA evaluated INL-CCP’s continued compliance with E PA-approved VE procedures for newly generated CH and RH waste and found compliance to b e adequate for both waste types.48

Technical Evaluation

The EPA inspectors reviewed BDRs, interviewed perso nnel and observed packaging operations to verify that VE continues to be performed by INL- CCP in accordance with approved procedures.

INL-CCP performs CH VE at the Radioactive Waste Man agement Complex (RWMC) ARP and

RH VE at INTEC. EPA determined that CH BDR Nos. IN- ARP-VE-002226 and IN-ARP-VE002227 were generated in accordance with approved p rocedure CCP-TP-006, Visual Examination Technique for INL Newly Generated TRU W aste Retrieved from Pits. Data were

recorded on the electronic data sheet Attachment 1 – CCP Waste Visual Examination Technique Data Form SCO# 798 Addendum 4, Windows XP 2002 MS E xcel 2003. The data sheets were signed and dated by two operators and a Visual Exam ination Expert (VEE). No NCRs were generated for these two BDRs. VE operators and VEE interviewed were able to provide answers to all EPA’s questions and were knowledgeable with regard to VE operations.

EPA determined that VE at CCP-INL continues to be p erformed by trained personnel and in accordance with approved procedures.

Summary of Visual Examination Findings and Concerns

The EPA inspection team did not identify any findin gs or concerns related to VE during this continued compliance inspection.

Changes to Visual Examination Tiering

There are no changes to the T1 or T2 designations t o VE as a result of this continued compliance inspection.

Visual Examination Conclusion

Based on the results of this evaluation and the dat a examined, EPA determines that INL-CCP demonstrated continued VE compliance.

7.0 SUMMARY OF RESULTS AND CONCLUSIONS

7.1 Findings and Concerns

There were no findings identified during this conti nued compliance inspection. The EPA inspection team identified one concern related to R TR as performed by INL-CCP which is discussed above and is provided in Attachment A.

7.2 Tiering Changes

There are no changes to the T1 or T2 designations i n any waste characterization area as a result of this inspection.49

7.3 Conclusions

The EPA inspection team determined that the INL-CCP waste characterization program activities continue to be technically adequate. EPA is not proposing any changes to the INL-CCP waste characterization program in the configuration at this time. The scope of the compliance decision is based on EPA’s inspection completed Nov ember 16–17, 2010.A-1 ATTACHMENT A

Real-Time Radiography Concern No. INL-CCP-CH-RTR-10 -01CR

Inspection No. EPA-INL-CCP-CH-11.10-24 Issue Number: INL-CCP-CH-RTR-10-01CR

Date: November 16, 2010, Revision 1
Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 1 Population size (if known): Unknown

Description of Issue:

A. Operators interviewed did not describe to EPA a con sistent method of calculation of liquid volume. For example, one operator always use d a rectangular formula and another attempted to use the closest standard shape formula. EPA is concerned that use of the calculation formulae has the potential for i nconsistent reporting of liquid

volumes.

B. Operators stated that they have not been provided a ny guidance for rounding and number of significant figures to use for reporting calculated liquid volumes. B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Mike Walentine, Bill Verlanic, Mark Pearcy

E. Additional Comments: EPA recognizes that the results of these calculatio ns are estimates and a high degree of precision is not expected.

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: December 7, 2010B-1ATTACHMENT B.1: REPLICATE TESTING DATA FOR DRUM ARP21969 – WAGSInstrument: WAGSDrum: ARP21969Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A234U Activity (Ci)2.39E-05 1.44E-05 6.03E-01 2.23E-05 1.35E-05 6.05E-01 1.93E-05 1.17E-05 6.06E-01238U Activity (Ci)9.92E-06 3.52E-06 3.55E-01 7.21E-06 2.68E-06 3.72E-01 8.46E-06 3.08E-06 3.64E-01238Pu Activity (Ci)2.54E-03 1.28E-03 5.04E-01 2.25E-03 1.15E-03 5.11E-01 5.14E-03 2.00E-03 3.89E-01239Pu Activity (Ci)8.49E-02 2.89E-02 3.40E-01 8.01E-02 2.73E-02 3.41E-01 8.07E-02 2.75E-02 3.41E-01240Pu Activity (Ci)1.71E-02 5.90E-03 3.45E-01 1.78E-02 6.24E-03 3.51E-01 1.83E-02 6.31E-03 3.45E-01242Pu Activity (Ci)3.12E-06 1.12E-06 3.59E-01 2.31E-06 1.42E-06 6.15E-01 3.20E-06 1.15E-06 3.59E-01241Am Activity (Ci)7.99E-02 2.73E-02 3.42E-01 7.33E-02 2.51E-02 3.42E-01 8.87E-02 3.04E-02 3.43E-0190Sr Activity (Ci)N/A N/A N/A137Cs Activity (Ci)N/A N/A N/ATRU Alpha Conc. (nCi/g)1.50E+03 3.27E+02 2.18E-01 1.41E+03 3.06E+02 2.17E-01 1.57E+03 3.38E+02 2.15E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A234U Activity (Ci)2.10E-05 1.27E-05 6.05E-01 1.64E-05 9.92E-06 6.05E-01 2.15E-05 1.30E-05 6.05E-01238U Activity (Ci)7.60E-06 2.84E-06 3.74E-01 8.53E-06 3.13E-06 3.67E-01 8.26E-06 2.98E-06 3.61E-01238Pu Activity (Ci)4.70E-03 1.89E-03 4.02E-01 2.35E-03 1.21E-03 5.15E-01 2.30E-03 1.24E-03 5.39E-01239Pu Activity (Ci)8.48E-02 2.89E-02 3.41E-01 8.24E-02 2.81E-02 3.41E-01 8.30E-02 2.83E-02 3.41E-01240Pu Activity (Ci)1.91E-02 6.59E-03 3.45E-01 1.85E-02 6.37E-03 3.44E-01 1.80E-02 6.22E-03 3.46E-01242Pu Activity (Ci)3.31E-06 1.19E-06 3.60E-01 3.17E-06 1.13E-06 3.57E-01 3.29E-06 1.18E-06 3.59E-01241Am Activity (Ci)7.62E-02 2.61E-02 3.43E-01 8.17E-02 2.80E-02 3.43E-01 7.85E-02 2.70E-02 3.44E-0190Sr Activity (Ci)N/A N/A N/A137Cs Activity (Ci)N/A N/A N/ATRU Alpha Conc. (nCi/g)1.50E+03 3.21E+02 2.14E-01 1.50E+03 3.27E+02 2.18E-01 1.48E+03 3.22E+02 2.18E-01B-2ATTACHMENT B.1: REPLICATE TESTING RESULTS FOR DRUMARP21969 – WAGSInstrument: WAGSDrum: ARP21969Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)2.39E-05 1.44E-05 2.01E-05 2.34E-06 1.17E-01 1.06E-01 9.99E-01238U Activity (Ci)9.92E-06 3.52E-06 8.01E-06 5.80E-07 7.23E-02 1.08E-01 9.99E-01238Pu Activity (Ci)2.54E-03 1.28E-03 3.35E-03 1.44E-03 4.31E-01 5.09E+00 2.78E-01239Pu Activity (Ci)8.49E-02 2.89E-02 8.22E-02 1.88E-03 2.28E-02 1.69E-02 1.00E+00240Pu Activity (Ci)1.71E-02 5.90E-03 1.83E-02 5.03E-04 2.74E-02 2.91E-02 1.00E+00242Pu Activity (Ci)3.12E-06 1.12E-06 3.06E-06 4.21E-07 1.38E-01 5.66E-01 9.67E-01241Am Activity (Ci)7.99E-02 2.73E-02 7.97E-02 5.91E-03 7.42E-02 1.87E-01 9.96E-0190Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)1.50E+03 3.27E+02 1.49E+03 5.72E+01 3.83E-02 1.22E-01 9.98E-01Quantity of Interest t Pr(x<|t|)x2Testt Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)1.48E+00 2.13E-01 Not Significant Not Significant238U Activity (Ci)3.01E+00 3.97E-02 Not SignificantSignificant238Pu Activity (Ci)-5.11E-01 6.36E-01 Not Significant Not Significant239Pu Activity (Ci)1.31E+00 2.60E-01Not Significant Not Significant240Pu Activity (Ci)-2.25E+00 8.76E-02Not Significant Not Significant242Pu Activity (Ci)1.39E-01 8.96E-01Not Significant Not Significant241Am Activity (Ci)3.40E-02 9.75E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)1.28E-01 9.05E-01Not Significant Not SignificantB-3ATTACHMENT B.2: REPLICATE TESTING DATA FOR DRUM ARP22225 – WAGSInstrument: WAGSDrum: ARP22225Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A234U Activity (Ci)5.74E-05 3.51E-05 6.12E-01 5.38E-05 3.29E-05 6.12E-01 5.91E-05 3.62E-05 6.13E-01238U Activity (Ci)6.27E-05 2.23E-05 3.56E-01 6.11E-05 2.17E-05 3.55E-01 6.04E-05 2.15E-05 3.56E-01238Pu Activity (Ci)4.06E-03 2.17E-03 5.35E-01 1.89E-03 9.82E-04 5.20E-01 1.76E-03 9.13E-04 5.19E-01239Pu Activity (Ci)6.46E-02 2.29E-02 3.55E-01 6.72E-02 2.38E-02 3.54E-01 6.25E-02 2.21E-02 3.54E-01240Pu Activity (Ci)1.80E-02 6.52E-03 3.62E-01 1.49E-02 5.43E-03 3.64E-01 1.39E-02 5.05E-03 3.63E-01242Pu Activity (Ci)6.12E-06 2.27E-06 3.71E-01 1.94E-06 1.21E-06 6.24E-01 1.80E-06 1.21E-06 6.72E-01241Am Activity (Ci)1.66E-01 5.89E-02 3.55E-01 1.60E-01 5.67E-02 3.54E-01 1.57E-01 5.56E-02 3.54E-0190Sr Activity (Ci)N/A N/A N/A137Cs Activity (Ci)N/A N/A N/ATRU Alpha Conc. (nCi/g)1.62E+03 4.08E+02 2.52E-01 1.56E+03 3.96E+02 2.54E-01 1.51E+03 3.85E+02 2.55E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A234U Activity (Ci)5.51E-05 3.37E-05 6.12E-01 5.46E-05 3.34E-05 6.12E-01 5.15E-05 3.15E-05 6.12E-01238U Activity (Ci)6.37E-05 2.26E-05 3.55E-01 6.63E-05 2.35E-05 3.54E-01 6.40E-05 2.27E-05 3.55E-01238Pu Activity (Ci)1.75E-03 9.12E-04 5.21E-01 1.77E-03 9.21E-04 5.20E-01 1.85E-03 9.61E-04 5.20E-01239Pu Activity (Ci)6.23E-02 2.21E-02 3.55E-01 6.30E-02 2.23E-02 3.54E-01 6.58E-02 2.33E-02 3.54E-01240Pu Activity (Ci)1.38E-02 5.05E-03 3.66E-01 1.40E-02 5.09E-03 3.64E-01 1.46E-02 5.31E-03 3.64E-01242Pu Activity (Ci)1.80E-06 1.12E-06 6.22E-01 1.82E-06 1.13E-06 6.21E-01 1.90E-06 1.18E-06 6.21E-01241Am Activity (Ci)1.68E-01 5.94E-02 3.54E-01 1.64E-01 5.84E-02 3.56E-01 1.80E-01 6.38E-02 3.54E-0190Sr Activity (Ci)N/A N/A N/A137Cs Activity (Ci)N/A N/A N/ATRU Alpha Conc. (nCi/g)1.57E+03 4.08E+02 2.60E-01 1.56E+03 4.02E+02 2.58E-01 1.68E+03 4.36E+02 2.60E-01B-4ATTACHMENT B.2: REPLICATE TESTING RESULTS FOR DRUMARP22225 – WAGSInstrument: WAGSDrum: ARP22225Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)5.74E-05 3.51E-05 5.48E-05 2.76E-06 5.04E-02 2.48E-02 1.00E+00238U Activity (Ci)6.27E-05 2.23E-05 6.31E-05 2.38E-06 3.78E-02 4.56E-02 1.00E+00238Pu Activity (Ci)4.06E-03 2.17E-03 1.80E-03 6.23E-05 3.45E-02 3.30E-03 1.00E+00239Pu Activity (Ci)6.46E-02 2.29E-02 6.42E-02 2.21E-03 3.44E-02 3.72E-02 1.00E+00240Pu Activity (Ci)1.80E-02 6.52E-03 1.42E-02 4.83E-04 3.39E-02 2.19E-02 1.00E+00242Pu Activity (Ci)6.12E-06 2.27E-06 1.85E-06 6.42E-08 3.47E-02 3.20E-03 1.00E+00241Am Activity (Ci)1.66E-01 5.89E-02 1.66E-01 8.96E-03 5.40E-02 9.25E-02 9.99E-0190Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)1.62E+03 4.08E+02 1.58E+03 6.27E+01 3.98E-02 9.44E-02 9.99E-01Quantity of Interestt Pr(x<|t|)x2Testt Test233U Activity (Ci)N/A N/ANot Applicable Not Applicable234U Activity (Ci)8.53E-01 4.42E-01Not Significant Not Significant238U Activity (Ci)-1.53E-01 8.86E-01Not Significant Not Significant238Pu Activity (Ci)3.31E+01 4.99E-06Not SignificantHighly Significant239Pu Activity (Ci)1.82E-01 8.64E-01Not Significant Not Significant240Pu Activity (Ci)7.11E+00 2.07E-03Not SignificantHighly Significant242Pu Activity (Ci)6.07E+01 4.41E-07Not SignificantHighly Significant241Am Activity (Ci)2.04E-02 9.85E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/ANot Applicable Not Applicable137Cs Activity (Ci)N/A N/ANot Applicable Not ApplicableTRU Alpha Conc. (nCi/g)6.41E-01 5.57E-01Not Significant Not SignificantB-5ATTACHMENT B.3: REPLICATE TESTING DATA FOR DRUM BN10381564 – SUPERHENCInstrument: SuperHENCDrum: BN10381564Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A234U Activity (Ci)N/A N/A N/A238U Activity (Ci)N/A N/A N/A238Pu Activity (Ci)1.40E-02 5.64E-03 4.02E-01 1.37E-02 5.50E-03 4.01E-01 1.55E-02 6.24E-03 4.01E-01239Pu Activity (Ci)4.58E-01 4.61E-02 1.01E-01 4.46E-01 4.43E-02 9.92E-02 5.06E-01 5.08E-02 1.00E-01240Pu Activity (Ci)1.02E-01 5.88E-03 5.78E-02 9.93E-02 5.45E-03 5.49E-02 1.13E-01 6.41E-03 5.70E-02242Pu Activity (Ci)1.32E-05 6.80E-06 5.15E-01 1.29E-05 6.63E-06 5.15E-01 1.46E-05 7.53E-06 5.15E-01241Am Activity (Ci)9.39E-02 2.19E-02 2.34E-01 9.02E-02 2.56E-02 2.84E-01 1.02E-01 2.91E-02 2.85E-0190Sr Activity (Ci)N/A N/A N/A137Cs Activity (Ci)N/A N/A N/ATRU Alpha Conc. (nCi/g)1.82E+03 1.93E+02 1.06E-01 1.77E+03 1.90E+02 1.07E-01 2.01E+03 2.17E+02 1.08E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A234U Activity (Ci)N/A N/A N/A238U Activity (Ci)N/A N/A N/A238Pu Activity (Ci)1.49E-02 6.00E-03 4.02E-01 1.47E-02 5.94E-03 4.04E-01 1.42E-02 5.68E-03 4.01E-01239Pu Activity (Ci)4.86E-01 5.04E-02 1.04E-01 4.79E-01 5.28E-02 1.10E-01 4.62E-01 4.54E-02 9.85E-02240Pu Activity (Ci)1.08E-01 6.76E-03 6.26E-02 1.06E-01 7.78E-03 7.31E-02 1.03E-01 5.49E-03 5.35E-02242Pu Activity (Ci)1.40E-05 7.23E-06 5.16E-01 1.38E-05 7.15E-06 5.17E-01 1.33E-05 6.86E-06 5.15E-01241Am Activity (Ci)9.82E-02 2.81E-02 2.86E-01 9.68E-02 2.79E-02 2.88E-01 9.33E-02 2.65E-02 2.84E-0190Sr Activity (Ci)N/A N/A N/A137Cs Activity (Ci)N/A N/A N/ATRU Alpha Conc. (nCi/g)1.93E+03 2.15E+02 1.11E-01 1.90E+03 2.23E+02 1.17E-01 1.84E+03 1.95E+02 1.06E-01B-6ATTACHMENT B.3: REPLICATE TESTING RESULTS FOR DRUMBN10381564 – SUPERHENCInstrument: SuperHENCDrum: BN10381564Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationx2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A238U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.40E-02 5.64E-03 1.46E-02 7.06E-04 4.83E-02 6.27E-02 1.00E+00239Pu Activity (Ci)4.58E-01 4.61E-02 4.76E-01 2.30E-02 4.83E-02 9.94E-01 9.11E-01240Pu Activity (Ci)1.02E-01 5.88E-03 1.06E-01 5.11E-03 4.83E-02 3.03E+00 5.53E-01242Pu Activity (Ci)1.32E-05 6.80E-06 1.37E-05 6.63E-07 4.83E-02 3.81E-02 1.00E+00241Am Activity (Ci)9.39E-02 2.19E-02 9.62E-02 4.65E-03 4.83E-02 1.79E-01 9.96E-0190Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)1.82E+03 1.93E+02 1.89E+03 9.15E+01 4.83E-02 8.94E-01 9.25E-01Quantity of Interest t Pr(x<|t|)x2Testt Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)N/A N/A Not Applicable Not Applicable238U Activity (Ci)N/A N/A Not Applicable Not Applicable238Pu Activity (Ci)-7.27E-01 5.08E-01 Not Significant Not Significant239Pu Activity (Ci)-7.27E-01 5.08E-01Not Significant Not Significant240Pu Activity (Ci)-7.27E-01 5.07E-01Not Significant Not Significant242Pu Activity (Ci)-7.27E-01 5.08E-01Not Significant Not Significant241Am Activity (Ci)-4.47E-01 6.78E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)-6.88E-01 5.30E-01Not Significant Not SignificantC.1-1 ATTACHMENT C.1

Acceptable Knowledge References – Contact-Handled W aste

CCP-TP-005, CCP Acceptable Knowledge Documentation, Carlsbad, New Mexico, Washington TRU Solutions, LLC., Revisions 18, 19 and 20, Novem ber 16, 2006, July 6, 2010, and November 1,

2010

ID-NTS-TTR-HET

Acceptable Knowledge Accuracy Report, Waste Stream ID-NTS-TTR-HET, Lot 1, June 30, 2010

CCP-AK-INL-009, CCP Acceptable Knowledge Summary Re port for Idaho National Laboratory

Nevada Test Site Lawrence Livermore National Labora tory Waste, Carlsbad, New Mexico, Washington TRU Solutions, LLC, Revision 1, May 19, 2009

CCP-AK-INL-014, Central Characterization Project Ac ceptable Knowledge Summary Report for Idaho National Laboratory Tonopah Test Range/Roller Coaster Project Contact-Handled Transuranic Waste, Waste Stream: ID-NTS-TTR-HET, Revision 0, Ju ly 15, 2009

CCP-PK-NTS-007, Central Characterization Project Pr ocess Knowledge Summary Report for Nevada Test Site Tonopah Test Range/Roller Coaster Project Contact-Handled Transuranic Waste, Carlsbad, New Mexico, Washington TRU Solutions, LLC , April 9, 2009

CCP-TP-005 Attachment 1, Documentation Checklist, J uly 23, 2009

CCP-TP-005 Attachment 4, Source Document Reference List, July 23, 2009

CCP-TP-005 Attachment 7, Radiological Data INL-NTS- TTR-HET, and associated AK-NDA Memorandum, August 14, 2009

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklis t, INL-NTS-TTR-HET, January 7, 2010

CCP AK Waste Stream Characterization Checklist, Oct ober 14, 2009

INL NTS AK Tracking Spreadsheet, October 1, 2010

List of BDRs, INL NTS-TTR-HET, dated November 8, 20 10

PTS Screen Shot Drum TTR-21A, provided November 17, 2010

Waste Stream Profile Form, Waste Stream ID-NTS-TTR- HET, December 30, 2009C.1-2

C1002, Letter to E.F. Di Sanza, Director Subject Co ntract No. DE-AC08-96NV11718 Notification for Placement of Clean Slate Fragments in TRU Pad C over Building, 1300-SL-00-0061, December 20, 1999

C1003, Letter to E.F. Di Sanza, Director Subject Co ntract,No. DE-AC-08-96NV11718 Concurrence for placement of corrective action unit (CAU) 407 R oller Coaster transuranic (TRU) waste in TRU Pad Cover Building (TPCB), 1300-SL-01-0095, Februar y 27, 2001

C1014, Interview with Lou Gregory Regarding NTS TRU Waste Management, October 1, 2008

C1024, Email from Lou Gregory to John Kleckner, re: Questions., November 5, 2008

DR005, Discrepancy Resolution re: Predominant Isoto pes for Waste Stream ID-NTS-TTR-HET, John Kleckner, January 7, 2010

M1005, Incoming Radioactive Material Checklist, 991 30R, December 6, 1999

M1025, TRU Inventory Scorecard, undated

P1012, Corrective Action Decision Document for Corr ective Action, Unit 407: Roller Coaster RADSAFE Area, Tonopah Test Range, Nevada, CAU 407 W aste Characterization and Disposal, DOE/NV-567, September, 1999 and July, 2000

P1013, Level 1 - Waste Characterization Waste Strea m Number: LRY5LLNTSCS06 Double Tracks Soil MEF. NO. 00437, undated

P1014, Waste Characterization Summary Waste Stream Number: LRY5LLFY00010 CAU 407, TTR Solid Soil, MEF No. F00011, undated

P1016, Corrective Action Investigation Plan for Cor rective Action Unit 486: Double Tracks Radsafe Area Nellis Air Force Range, Nevada, DOE/NV-523, Oc tober 1998

P1018, In Situ Radiological Surveying at the Double Tracks Site, DOE/NV/11718-013, April 1996

P1023, Clean Slate 1, Corrective Action Decision Do cument, Corrective Action Unit No. 412, DOE/NV-472, April 1997

P1024, Clean Slate 1 Closure Report (Nevada Environ mental Restoration Project), DOE/NV/11718- 159, November 1997

P1025, Closure Report for Corrective Action Unit 40 7; Roller Coaster RADSAFE Area; Tonopah Test Range, Nevada, DOE/NV-694-Rev, December 12, 20 01

P1032, Radiological Dose Assessment for Residual Ra dioactive Material in Soil at the Clean Slate Sites 1, 2, and 3, Tonopah Test Range, DOE/NV-482, UC-700, June 1997C.1-3

P1033, Double Tracks Test Site Characterization Rep ort, DOE/NV-484, UC-700, May 1996

P1036, Nevada Environmental Restoration Project Dou ble Tracks Closure Report, DOE/NV-11718- 113, UC-802, June 1997

P1088, Operation Roller Coaster, Project Officers R eport – Project 2.6d, Special Particulate Analysis (Soil), POR-2509 (WT-2509), May 26, 1966

P1096, Nevada Environmental Restoration Project, Cl ean Slate 1 Corrective Action Plan, DOE/NV/11718-100 (UC-700), April 1997

P1099, Nevada Environmental Restoration Project, Do uble Tracks Interim Corrective Action Plan, DOE/NV/11718-112, June 1996

P1107, Clean Slate Corrective Action Investigation Plan, DOE/NV-456, May 1996

U1010, WEF Supervisor Logbook Excerpt, February 23, 2006

U1011, WEF Visual Examination Expert Logbook Excerp t, February 23, 2006

ID-NTLBL-S5400 and ID-NTLBL-S3900

Acceptable Knowledge Accuracy Report, Waste Stream ID-NTLBL-S5400, Lot 1, November 10,

2010

Acceptable Knowledge Accuracy Report: Idaho Nationa l Laboratory Waste Stream ID-NTLBLS3900, Lot 1, May 25, 2010

CCP-AK-INL-009, Central Characterization Project Ac ceptable Knowledge Summary Report for Idaho National Laboratory Nevada Test Site Lawrence Livermore National Laboratory Waste, Carlsbad, New Mexico, Washington TRU Solutions, LLC , Revision 1, May 19, 2009

CCP-AK-INL-010, Central Characterization Project Ac ceptable Knowledge Summary Report for Idaho National Laboratory Nevada Test Site Lawrence Berkeley National Laboratory Waste, Waste Streams:ID-NTLBL-S5400, ID-NTLBL-S3900, Revision 0, June 18, 2009

CCP-AK-NTS-3, Central Characterization Project Acce ptable Knowledge Summary Report for Nevada Test Site Lawrence Berkeley Laboratory Waste , Carlsbad, New Mexico, Washington TRU Solutions, LLC, Revision 4, December 7, 2005

CCP-PK-NTS-003, Central Characterization Project Pr ocess Knowledge Summary Report for Nevada Test Site Lawrence Berkeley National Laborat ory Waste, Carlsbad, New Mexico, Washington TRU Solutions, LLC, Revision 8, November 6, 2008

CCP-TP-005 Attachment 1, Documentation Checklist, I D-NTLBL-S3900, July 15, 2009C.1-4

CCP-TP-005 Attachment 1, Documentation Checklist, I D-NTLBL-S5400, July 15, 2009

CCP-TP-005 Attachment 4, Source Document Reference List, ID-NTLBL-S3900, July 15, 2009

CCP-TP-005 Attachment 4, Source Document Reference List, ID-NTLBL-S5400, July 15, 2009

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, Waste Stream ID-NTLBL-S3900, June 11, 2009

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, Waste Stream ID-NTLBL-S5400, June 11, 2009

CCP-TP-005 Attachment 7, Radiological Data ID-NTLBL -S3900, and associated AK-NDA Memorandum, June 25, 2009

CCP-TP-005 Attachment 7, Radiological Data I ID-NTL BL-S5400, and associated AK-NDA Memorandum, June 25, 2009

CCP-TP-005 Attachment 8, Drum List Waste Stream ID- NTLBL-S3900, June 11, 2009

CCP-TP-005 Attachment 8, Drum List Waste Stream ID- NTLBL-S5400, June 11, 2009

CCP Waste Stream Characterization Checklist, ID-NTL BL-S3900/S5400, September 25, 2009

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklis t, ID-NTLBL-S5400, November 9, 2010

CCP Waste Stream Characterization Checklist, ID-NTL BL-S5400, September 25, 2009

INL NTS AK Tracking Spreadsheet, October 1, 2010

LBNL-C-13, Lawrence Berkley Laboratory Defense Dete rmination, July 8, 2003

List of BDRs, ID-NTLBL-S5400 and S3900, dated Novem ber 8, 2010

Waste Stream Profile Form, Waste Stream ID-NTLBL-S3 900, March 25, 2010

Waste Stream Profile Form, Waste Stream ID-NTLBL-S5 400, March 25, 2010

C101, Telecon between Jeff Harrison and Jim Haley/H arry Jelonic, LLNL - TRU Waste Generated at Lawrence Berkeley Laboratory, (LBL), March 24, 1998

C142, Calculation of Individual and Total Radionucl ide Masses and Activities for Waste Stream ID-NTLBL-S5400, May 15, 2009

DR002, Discrepancy Resolution – Additional Physical Form, February 20, 2005C.1-5

P025, NTS TRU Waste Inventory Database, November 18 , 1997

P094, Acceptable Knowledge Document for NTS-Stored Transuranic Waste - Lawrence Berkeley Laboratory Waste, B-2151/00.03, August 2000

P095, Bechtel Nevada TRU Waste Examination, Segrega tion, and Repacking Procedure, OP-2151.402, Revision 2, June 25, 2001

P098, Central Characterization Project Acceptable K nowledge Summary Report for Ernest Orlando, Lawrence Berkeley National Laboratory Contact-Handl ed TRU Waste, Waste Stream BLCHDN.001 CCP-AK-LBNL-001, Revision 0, June 30, 20 04

U001, Assessment of Transuranic Waste Inventory Sto red at the Nevada Test Site, April 18, 1991

U003, Databases Used for the Inventory Assessments of the TRU Drums Stored at DOE’s Nevada Test Site (1974-1990), March 13, 1991

U014, Uncontrolled NTS TRU Waste Inventory Details, March 1998

U015, Uncontrolled NTS TRU Waste Inventory Details, March 1998

U016, Excerpts from Nevada Test Site Shipping Recor ds, 1974-1986

U029, Building 612 Radioactive Waste Logbooks, 1974 -1985

U051, TRU Waste Packing Log, November 18, 2004

U052, TRU_DS Database Information and TRU_DS User's Guide, OI-2151.401, Version 5.0, September 2000

U061, Radiological Analysis for Waste Streams NTLBL -S5400 and NTLBL-S3900, January 2005

U062, CCP-AK-LBNL-001 Shoebox and Liquid Treatment Chemical Data, January 2005

U065, Real Time Radiography (RTR) and Radiography o f LBL Containers at the Nevada Test Site, March 9, 2005, March 10, 2005, February 14, 2005, F ebruary 15, 2005

U067, CCP NDA Radiological Re-Evaluation for the NT LBL-S5400 Waste Stream, September 2005

U072, Container Spreadsheet (Scorecard), September 24, 2008

U074, Visual Examination Expert Logbook (select ent ries from 7/11 – 7/23), April 7, 2005 through August 11, 2005

U084, Holding Container Inventory Log, October 9, 2 008C.1-6

U085, Combined NDA Radiological Datasheets, various dates

U103, Container Documentation and Prescreen Data fo r Waste Streams ID-NTLBL-S5400 and ID-NTLBL-S3900, various dates

ID-SDA-DEBRIS, ID-SDA-SLUDGE, and ID-SDA-SOIL

Acceptable Knowledge Accuracy Report, Waste Stream ID-SDA-DEBRIS, Lots 1-28, April 15, 2010

Acceptable Knowledge Accuracy Report, Waste Stream ID-SDA-SLUDGE, Lots 1-185, April 27,

2010

Acceptable Knowledge Accuracy Report, Waste Stream ID-SDA-SOIL, Lots 1-37, April 15, 2010

CCP-AK-INL-001, Central Characterization Project Ac ceptable Knowledge Summary Report for Waste Retrieved from Designated Areas within the Su bsurface Disposal Area at the Idaho National Laboratory Transuranic Waste Streams ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID-SDA-SOIL, Revisions 6, 7, 8, and 9, February 7, 2008, October 27, 2008, September 8, 2009, and September 8,

2010

CCP-TP-005 Attachment 1, Documentation Checklist, W aste Stream: ID-SDA-DEBRIS, June 3,

2010

CCP-TP-005 Attachment 1, Documentation Checklist, W aste Stream: ID-SDA-SLUDGE, June 3,

2010

CCP-TP-005 Attachment 1, Documentation Checklist, W aste Stream: ID-SDA-SOIL, June 3, 2010

CCP-TP-005 Attachment 4, Source Document Reference List, June 3, 2010

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, Waste Stream ID-SDA-DEBRIS, June 19, 2009

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, Waste Stream ID-SDA-SLUDGE, June 19, 2009

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, Waste Stream ID-SDA-SOIL, June 19, 2009

CCP-TP-005 Attachment 7, Radiological Data ID-SDA-D EBRIS, ID-SDA-SLUDGE, ID-SDASOIL, and associated AK-NDA Memorandum, August 14, 2009

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklis t, ID-SDA-SLUDGE, October 30, 2008

CCP-TP-005 Attachment 10, AK Re-Evaluation Checklis t, ID-SDA-SOIL, October 12, 2009C.1-7

CCP AK Waste Stream Characterization Checklists, ID -SDA-DEBRIS, various lots, various dates

CCP AK Waste Stream Characterization Checklists, ID -SDA-SLUDGE, various lots, various dates

CCP AK Waste Stream Characterization Checklists, ID -SDA-SOIL, various lots, various dates

INL AK ARP Tracking Spreadsheet, October 29, 2010

PTS Screen Shot Drum ARP06227, provided November 17 , 2010

PTS Screen Shot Drum ARP15566, provided November 17 , 2010

PTS Screen Shot Drum ARP20413, provided November 17 , 2010

Waste Isolation Pilot Plant Container Data Report, Drum ARP06227, November 16, 2010

Waste Isolation Pilot Plant Container Data Report, Drum ARP15566, November 16, 2010

Waste Isolation Pilot Plant Container Data Report, Drum ARP20413, November 16, 2010

Waste Stream Profile Form, Waste Stream ID-SDA-DEBR IS, February 21, 2007

Waste Stream Profile Form, Waste Stream ID-SDA- SLU DGE, September 25, 2007

Waste Stream Profile Form, Waste Stream ID-SDA-SOIL , Revision 1, October 7, 2009

ID-C114, Email from Lisa Frost to Scott Smith and C arrie Johnson, Pit 9 & GEM & Lab Waste, March 11, 2010

ID-P092, History of Buried Transuranic Waste at INE L, WPM 77-3, March 1, 1977

ID-P377, Waste Management Plan for the OU 7-10 Glov ebox Excavator Method Project, INEEL/EXT-02-00767, Revision 1, September 2003

ID-P380, Health and Safety Plan for OU 7-10 Glovebo x Excavator Method Project Operations, INEEL/EXT-02-01117, Revision 7, March 2004

ID-P399, Idaho Completion Project’s Accelerated Ret rieval Project Overview Of The Pit 4 NonTime Critical Removal Action, ICP/CON-04-00598 Prep rint, February 27-March 3, 2005

ID-P402, CH2M-WG Idaho Process Knowledge Summary Re port for CH TRU Waste and Mixed Low-Level Waste Generated at INTEC and RWMC Analyti cal Laboratories in Support of AMWTP Sampling Activities, Waste Matrix Codes S5490 and S 3900, RPT-670, Revision 2, January 2010

ID-P403, Waste Disposition Plan for ICP Laboratory Activities, PLN-3007, Revision 0, February 23,

2009C.1-8

ID-P404, Analytical Laboratory Waste Management, AC LP-0.040, Revision 9, August 24, 2009

ID-U313, Radioactive Waste Management Complex Map, G10-2355-07, not dated

ID-U329, Visual Examination Data for ARP-I, Decembe r 11, 2006

ID-U343, Non-Rocky Flats Shipping Records ARP-III ( P06P01), July 31, 2008

ID-U344, Non-Rocky Flats Shipping Records ARP-IV (P 05P01), December 4, 1964 to December 13,

1966

ID-U345, Non-Rocky Flats Shipping Records ARP-V (P0 9P03-P09P04), November 13, 1967 to September 11, 1968

ID-U355, GEM Assay Data and Drum Descriptions, July 2, 2008

ID-U376, CERCLA Storage/Staging Area, RWMC- TRAILER 14-CARGO-A, CSA_1539N, July 20, 2010

ID-U377, Waste Determination & Disposition Form (WD DF), Sample Residue and Analytical Debris from ARP Samples, WDDF Number: RWMC10012.R1, July 2 2, 2010

INTEC-P002, A History of the Radioactive Waste Mana gement Complex at the Idaho National Engineering Laboratory, WM-F1-81-003, Revision 3, J uly 1, 1985

RF-P356, Field Sampling Plan for the OU-7-10 Gloveb ox Excavator Method Project, INEEL/EXT02-00542, Revision 2, October 2, 2003

RF-U1306, Rocky Flats shipping records for ARP-III (P06P01) in the RWMC SDA, February 12, 1968 to September 3, 1968

RF-U1307, Rocky Flats shipping records for ARP-IV ( P05P01) in the TWMC SDA, July 22, 1964 to November 18, 1966

RF-U1308, Rocky Flats shipping records for ARP- V ( P09P03, P09P04) in the RWMC SDA, February 9, 1968 to September 24, 1968C.2-1 ATTACHMENT C.2

Acceptable Knowledge References – Remote-Handled Wa ste

DOE/WIPP-02-3214, Remote-Handled TRU Waste Characte rization Program Implementation Plan, Carlsbad, New Mexico, U.S. DOE Carlsbad, Revision 0 d, October 30, 2003

CCP-TP-506, CCP Preparation of the Remote-Handled T ransuranic Waste Acceptable Knowledge Characterization Reconciliation Report, Revision 2, June 8, 2006

RH INL AK Tracking Spreadsheet, September 27, 2010

ID-HFEF-S5400-RH

CCP-AK-ANLE-501, Central Characterization Project R emote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d Transuranic Debris Waste From Argonne National Laboratory-East, Revision 2, May 10, 2010

CCP-AK-INL-580, Central Characterization Project Ac ceptable Knowledge Summary Report

For Remote-Handled Transuranic Debris Waste from Ma terials and Fuels Complex Hot Fuel Examination Facility at the Idaho National Laborato ry Waste Stream ID-HFEF-S5400-RH, Revision 2, June 1, 2010

CCP-AK-INL-581, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report For Remote-Handle d Transuranic Debris Waste from the Hot Fuel Examination Facility (HFEF) at the Idaho National L aboratory, Revision 1, April 30, 2010

CCP-AK-INL-582, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for INL RH Waste Stream: ID-HFEF-S5400-RH, Revision 1, May 27, 2010

CCP-TP-005 Attachment 1, Documentation Checklist, I D-HFEF-S5400-RH, July 15, 2009

CCP-TP-005 Attachment 4, Source Document Reference List, ID-HFEF-S5400-RH, November 10,

2010

CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, Packaging, Waste Stream ID-HFEF-S5400-RH, November 12, 2009

CCP-TP-005 Attachment 8, Drum List Waste Stream ID- HFEF-S5400-RH, November 12, 2009

Draft Acceptable Knowledge Accuracy Report, Waste S tream ID-HFEF-S5400-RH, Lots 1-9, October 12, 2009C.2-2

NCR-RHINL-0500-10, Surface Dose Rate for Container IDAWANL870105A measured 70 mrem/hr, not the required 200 mrem/hr, February 10, 2010

NCR-RHINL-0507-10, Addition of containers to the AK tracking spreadsheet, May 25, 2010

NCR-RHINL-0514-10, Identification of negative conta iner weight on a waste conversion record, October 18, 2010

NCR-RHINL-0515-10, Drums N154B, N153A and SN151A di d not meet the decay heat limits specified in approved RH-TRUCON codes, November 2, 2010

PTS screen shots for waste drum SN152A, provided No vember 16, 2010

Waste Stream Profile Form for Waste Stream ID-HFEF- S5400-RH, February 12, 2010

WDS Print-out 133 HFEF Drums, Drum SN152A, as of No vember 13, 2010

ID-INTEC-RH

Acceptable Knowledge Accuracy Report: Idaho Nationa l Laboratories Waste Stream Number IDINTEC-RH, Lot 1, November 5, 2010

CCP-AK-INL-550, Central Characterization Project Ac ceptable Knowledge Summary Report for

Stored Remote-Handled Transuranic Debris from the I daho Nuclear Technology and Engineering Center at the Idaho National Laboratory Waste Strea m ID-INTEC-RH, Revision 1, March 22, 2010

CCP-AK-INL-551, Central Characterization Project Ra diological Characterization Technical Report for the Idaho Nuclear Technology and Engineering Ce nter (INTEC) Remote-Handled Transuranic Debris Waste, Revision 0, October 20, 2009

CCP-AK-INL-552, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for INL Waste Stream: ID-INTEC-RH, Revision 0, April 2, 2009

CCP-AK-INL-555, Central Characterization Project Sa mpling and Analysis Plan, for Stored RemoteHandled Transuranic Debris from the Idaho Nuclear T echnology and Engineering Center at the Idaho National Laboratory, Revision 0, March 9, 2009

CCP-TP-005 Attachment 1, Documentation Checklist, I D-INTEC-RH, December 16, 2009

CCP-TP-005 Attachment 4, Source Document Reference List, ID-INTEC-RH, November 10, 2010

CCP-TP-005, Attachment 6, Waste Form, Waste Materia l Parameters, Prohibited Items, Packaging, Waste Stream ID-INTEC-RH, November 12, 2009

CCP-TP-005, Attachment 8, Drum List Waste Stream ID -INTEC-RH, November 12, 2009C.2-3

NCR-RHINL-0501-10, Container IDICOOOO00427 was samp led for radiochemistry analysis to develop the scaling factors. The analytical laborat ory has sample residues to be placed back into the drum. The dose is too high on the sample residues t o dispose as laboratory waste, March 16, 2010

NCR-RHINL-D502-10, New Sample Measurement and Conve rsion Record, March 16, 2010

NCR-RHINL-0504-09, The amount of organic waste by v olume was not recorded for the containers listed in box 3, June 1, 2009

NCR-RHINL-0507-09, Misidentification of Smear Sampl e as Solid Sample, September 9, 2009

NCR-RHINL-0512-09, The scaling factors used to calc ulated the results in BDR INLRHDTC09004

for the containers listed in Block 3 were incorrect , December 8, 2009

PTS Screen Shots Containers IDIC000000427 and 460, November 8, 2010

Waste Stream Profile Form, ID-INTEC-RH, September 1 5, 2010

WDS Screen Shots, INTEC Stream, November 9, 2010

ID-MFC-S5400-RH

CCP-AK-INL-540, Central Characterization Project Ac ceptable Knowledge Summary Report for

Remote-Handled Transuranic Waste from the Materials and Fuels Complex at the Idaho National Laboratory Waste Streams ID-MFC-S5400-RH and ID-MFC -SOLID-RH, Revision 2, November 8,

2010

CCP-AK-INL-541, Central Characterization Project Ra diological Characterization Technical Report

for Remote-Handled Transuranic Debris Waste from th e Materials and Fuels Complex at the Idaho National Laboratory, Revision 1, December 2, 2009

CCP-AK-INL-542, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for INL Waste Stream: ID-MFC-S5400-RH, Revision 0, July 28, 2008

CCP-TP-005 Attachment 1, Documentation Checklist, I D-MFC-S5400-RH, May 25, 2010

CCP-TP-005 Attachment 4, Source Document Reference List, ID-MFC-S5400-RH, June 10, 2010

CCP-TP-005, Attachment 6, Waste Form, Waste Materia l Parameters, Prohibited Items, Packaging, Waste Stream ID-MFC-S5400-RH, June 10, 2010

CCP-TP-005, Attachment 8, Drum List Waste Stream ID -MFC-S5400-RH, February 2, 2010

Draft Acceptable Knowledge Accuracy Report: Idaho N ational Laboratories Waste Stream Number ID-MFC-S5400-RH, April 15, 2010C.2-4

NCR-RHINL-0509-10, The ITR did not properly review the Audio/Video for container IDAWANL880065A. The RTR operator called out the wro ng date and the ITR did not resolve this with the RTR operator, July 20, 2010

PTS Screen Shots Containers IDAWANL880064A, 64B, 65 A, 65B, 68A, 68B, 134A, and 134B, November 8, 2010

Waste Stream Profile Form, ID-MFC-S5400-RH, June 24 , 2010

WDS Shipping Information Spreadsheet, ID-MFC-S5400, November 9, 2010C.3-1 ATTACHMENT C.3

Nondestructive Assay References

Audit Information summarizing numbers of containers and specific configurations assayed each year 2007 through 2010, prepared for inspection by Steph anie McElhaney

CCP WAGS Procedure: CCP-TP-010, Revision 3

CCP-Idaho National Laboratory List of Qualified Ind ividuals, 11/15/1010, 3:21:27 PM, 14 pages, prepared at request of EPA Inspectors

CCP-INL-WAGS-08-002, WAGS Multi-Curve Efficiency Ca libration Extension Addendum, Revision 0, April 10, 2008; 16 pages

CCP-INL-WAGS-10-005, September 20. 2010, Calibratio n Verification of the WAGS System after Detector Replacement and Energy Calibration

CCP-SHENC-10-002, Revision 0, INL SuperHENC 2-Puck SWB Interfering Matrix Measurements, May 10, 2010

CCP-SHENC-10-003, Revision 0, INL SuperHENC 55-Gall on Combustible Interfering Matrix Measurements, May 10, 2010

CCP-SHENC-10-004, Revision 0, INL SuperHENC Weekly Interfering Matrix Measurements, September 27, 2010

CCP-TP-109, Revision 6; CCP Data Reviewing, Validat ing and Reporting Procedure

CCP-TP-146, Revision 7; CCP SuperHENC Operating Pro cedure

CCP-TP-148, Revision 5; CCP SuperHENC Data Reviewin g, Validating and Reporting Procedure

CCP-TP-170, Revision 2; CCP SuperHENC Calibration P rocedure

Operator Aid posted in WAGS Control Area: CCP-INL-1 74, WAGS Pulser Parameter Data, Peak Centroid Limits, dated December 21, 2009

Standing Order posted in WAGS Control Area: CCP-INL -06-007, Pulser Monitoring, dated June 7,

2006

Standing Orders posted in WAGS Control Area: CCP-IN L-005-003; CCP-INL-150; CCP-INL-009

Summary of Drums Assayed on SGRS, WAGS and HENC, Ja nuary 2010 to November 16, 2010, prepared for inspection by Preston AbbottC.3-2

SuperHENC BDR No. INNDA BO9016

SuperHENC Calibration Report: BII-5221-CVR-001, Rev ision 0

SuperHENC Operational Logbook, page 40, correspondi ng to day of EPA inspection

WAGS Batch Data Report INNDAW0090241, consisting of two drums, ARP10173 and ARP10403

WAGS Operational Logbook, page 133, corresponding t o day of EPA inspection